FAC Explorer

Audit 35847

FY End
2022-04-30
Total Expended
$13.14M
Findings
16
Programs
13
Organization: Simpson University (CO)
Year: 2022 Accepted: 2023-01-30
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
33520 2022-002 Significant Deficiency Yes N
33521 2022-002 Significant Deficiency Yes N
33522 2022-002 Significant Deficiency Yes N
33523 2022-002 Significant Deficiency Yes N
33524 2022-002 Significant Deficiency Yes N
33525 2022-003 Significant Deficiency Yes L
33526 2022-003 Significant Deficiency Yes L
38581 2022-004 - - G
609962 2022-002 Significant Deficiency Yes N
609963 2022-002 Significant Deficiency Yes N
609964 2022-002 Significant Deficiency Yes N
609965 2022-002 Significant Deficiency Yes N
609966 2022-002 Significant Deficiency Yes N
609967 2022-003 Significant Deficiency Yes L
609968 2022-003 Significant Deficiency Yes L
615023 2022-004 - - G

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $6.12M Yes 1
84.063 Federal Pell Grant Program $1.79M Yes 1
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $1.55M Yes 1
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $1.18M Yes 2
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $544,688 - 0
84.047 Trio_upward Bound - Dunsmuir $350,224 Yes 0
84.047 Trio_upward Bound - West Valley $338,451 Yes 0
84.047 Trio_upward Bound - Anderson $299,684 Yes 0
84.042 Trio_student Support Services $283,383 Yes 0
84.047 Trio_upward Bound - Mount Shasta $279,061 Yes 0
84.038 Federal Perkins Loan Program $246,482 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $85,098 Yes 1
84.033 Federal Work-Study Program $78,587 Yes 1

Contacts

Name Title Type
DKLXHQNHDBH4 Michelle Butcher Auditee
5302264933 Christopher Gordon, CPA Auditor
No contacts on file

Notes to SEFA

Title: COVID-19 HEERF FUNDS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Simpson University and Simpson University Foundation (University) under programs of the federal government for the year ending April 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The CARES, CRRSSA and ARP Acts required that the University spend a minimum of $2,193,298 of the HEERF allocations for emergency financial aid grants to students. As of April 30, 2022, the University has $81,890 remaining to be disbursed to students by June 30, 2023 to meet this minimum. Emergency financial aid grants were disbursed to students subsequently in fiscal year 2023.
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUAR Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Simpson University and Simpson University Foundation (University) under programs of the federal government for the year ending April 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees. The University did receive a Small Business Administration (SBA) Paycheck Protection Program (PPP) loan in the amount of $1,976,815. (See Note 7 to the financial statements). The SBA has indicated that PPP loans are not subject to Uniform Guidance audit requirements and therefore, the PPP loan is not included in the schedule.
Title: FEDERAL PERKINS LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Simpson University and Simpson University Foundation (University) under programs of the federal government for the year ending April 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See table in SEFA Note 5.
Title: RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Simpson University and Simpson University Foundation (University) under programs of the federal government for the year ending April 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See table in SEFA note 3.
Title: ZONE ALTERNATIVE Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Simpson University and Simpson University Foundation (University) under programs of the federal government for the year ending April 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University is operating under the Provisional Certification Alternative for failure to meet the Department of Education's standards of financial responsibility. The University must comply with all the requirements specified for the Provisional Certification Alternative including the Zone Alternative. As part of the audit procedures, the School's compliance with the Zone Alternative including their administration of the heightened cash monitoring payment method, disbursing aid and paying out credit balances before requesting reimbursement and notification requirements was tested. No non-compliance with the requirements was noted.

Finding Details

Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-003
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-003
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-004
Education Stabilization Fund-ARP Earmarking DEPARTMENT OF EDUCATION ALN#: 84.425F Federal Award Identification #: P425F203100 Condition: The University did not use some institutional funds from the American Rescue Plan (ARP) HEERF allocation for conducting direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA as required by the ARP. Criteria: ARP HEERF (a) (1) Institutional portion Questioned Costs: None Context: During the audit, it was noted that the University did not have evidence of using HEERF funds for direct outreach to financial aid applicants. Management indicated that an e-mail notification was provided to students but was unable to provide this as the employee responsible for this task is no longer employed by the University. Cause: Staffing challenges brought on by COVID. Effect: The University was not in compliance with the ARP earmarking requirements. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University conduct the direct outreach to financial aid applicants or work with the IT department in obtaining the evidence that it was completed in fiscal year 2022. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-003
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-003
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-004
Education Stabilization Fund-ARP Earmarking DEPARTMENT OF EDUCATION ALN#: 84.425F Federal Award Identification #: P425F203100 Condition: The University did not use some institutional funds from the American Rescue Plan (ARP) HEERF allocation for conducting direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA as required by the ARP. Criteria: ARP HEERF (a) (1) Institutional portion Questioned Costs: None Context: During the audit, it was noted that the University did not have evidence of using HEERF funds for direct outreach to financial aid applicants. Management indicated that an e-mail notification was provided to students but was unable to provide this as the employee responsible for this task is no longer employed by the University. Cause: Staffing challenges brought on by COVID. Effect: The University was not in compliance with the ARP earmarking requirements. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University conduct the direct outreach to financial aid applicants or work with the IT department in obtaining the evidence that it was completed in fiscal year 2022. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.