2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition
Compliance Requirement Procurement
Finding Type Material Weakness in Internal Controls and Material Noncompliance
Federal Agency US Department of Education
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation.
2 CFR § 200.319, Competition
All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320.
2 CFR § 200.320, Procurement Methods
c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies:
The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);
The procurement transaction can only be fulfilled by a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or
After soliciting several sources, competition is determined inadequate.
Condition
From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition.
Cause
The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations.
Effect
Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
$434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications.
Recommendation
We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition
Compliance Requirement Procurement
Finding Type Material Weakness in Internal Controls and Material Noncompliance
Federal Agency US Department of Education
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation.
2 CFR § 200.319, Competition
All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320.
2 CFR § 200.320, Procurement Methods
c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies:
The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);
The procurement transaction can only be fulfilled by a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or
After soliciting several sources, competition is determined inadequate.
Condition
From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition.
Cause
The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations.
Effect
Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
$434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications.
Recommendation
We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking
Compliance Requirement Cash Management
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
2 CFR § 200.305 (b) – Federal Payment
.....
Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition
Higher Education Institutional Aid
From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Twenty-four instances where the three-day rule was exceeded.
Five instances where the specific drawdown related to the disbursement could not be identified.
TRIO Cluster Programs
From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following:
Fourteen instances where the three-day rule was exceeded.
Three instances where the specific drawdown related to the disbursement could not be identified.
Cause
Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown.
Effect
Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
None.
Recommendation
We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-003 Drawdowns Segregation of Duties
Compliance Requirement Cash management
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
ALN 84.042A
Federal Program TRIO Cluster Program
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
2 CFR § 200.303, Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown.
Cause
Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown.
Effect
The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Recommendations
We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition
Compliance Requirement Procurement
Finding Type Material Weakness in Internal Controls and Material Noncompliance
Federal Agency US Department of Education
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation.
2 CFR § 200.319, Competition
All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320.
2 CFR § 200.320, Procurement Methods
c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies:
The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);
The procurement transaction can only be fulfilled by a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or
After soliciting several sources, competition is determined inadequate.
Condition
From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition.
Cause
The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations.
Effect
Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
$434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications.
Recommendation
We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition
Compliance Requirement Procurement
Finding Type Material Weakness in Internal Controls and Material Noncompliance
Federal Agency US Department of Education
ALN 84.425F and 84.425L
Federal Program COVID-19 - Education Stabilization Fund
Criteria
Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation.
2 CFR § 200.319, Competition
All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320.
2 CFR § 200.320, Procurement Methods
c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies:
The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);
The procurement transaction can only be fulfilled by a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or
After soliciting several sources, competition is determined inadequate.
Condition
From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition.
Cause
The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations.
Effect
Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding.
Questioned Costs
$434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications.
Recommendation
We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)