Finding 2022-003 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Student Federal Financial Assistance Listing #84.425E P425E200919-20B Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Condition: The University over-awarded Higher Education Emergency Relief Fund (HEERF) funding to one student based on its determination over eligibility of the student portion of HEERF funding, which is awarded based on (1) expected family contribution and (2) enrollment status. The student was awarded based on fulltime enrollment; however, the student?s enrollment status was part-time. Cause: The student listing, prepared by the registrar?s office and used by the financial aid office to determine the allocation of student funding improperly counted credit hours more than once for certain students. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that disallowed expenditures will be charged to the federal award. Questioned Costs: No questioned costs (students were overpaid) Context: A nonstatistical sample of 60 ($82,250) students out of a total of approximately 1,270 ($1,627,825) students were tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management review procedures and control processes to comply with the federal requirements noted above. Views of Responsible Officials: Management agrees with the finding and the recommendation.
Finding 2022-004 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Federal Financial Assistance Listing #84.425F P425F200756-20A and P425F200756-20B Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The University?s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the University did not retain documentation to support the procedures it performed to ensure compliance with procurement, suspension, and debarment. Cause: The University does not typically use federal financial assistance to procure goods and services; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with procurement, suspension, and debarment could result in procurements that do not conform with Uniform Guidance. Questioned Costs: None reported Context: A non-statistical sample of 4 ($291,493) out of 21 ($392,941) purchases / contracts with expenditures over the micropurchase threshold of $3,000 were tested for procurement. In addition, suspension and debarment was applicable to two vendors. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements. Views of Responsible Officials: Management agrees with the finding and the recommendation.
Finding 2022-003 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Student Federal Financial Assistance Listing #84.425E P425E200919-20B Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Condition: The University over-awarded Higher Education Emergency Relief Fund (HEERF) funding to one student based on its determination over eligibility of the student portion of HEERF funding, which is awarded based on (1) expected family contribution and (2) enrollment status. The student was awarded based on fulltime enrollment; however, the student?s enrollment status was part-time. Cause: The student listing, prepared by the registrar?s office and used by the financial aid office to determine the allocation of student funding improperly counted credit hours more than once for certain students. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that disallowed expenditures will be charged to the federal award. Questioned Costs: No questioned costs (students were overpaid) Context: A nonstatistical sample of 60 ($82,250) students out of a total of approximately 1,270 ($1,627,825) students were tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management review procedures and control processes to comply with the federal requirements noted above. Views of Responsible Officials: Management agrees with the finding and the recommendation.
Finding 2022-004 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Federal Financial Assistance Listing #84.425F P425F200756-20A and P425F200756-20B Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The University?s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the University did not retain documentation to support the procedures it performed to ensure compliance with procurement, suspension, and debarment. Cause: The University does not typically use federal financial assistance to procure goods and services; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with procurement, suspension, and debarment could result in procurements that do not conform with Uniform Guidance. Questioned Costs: None reported Context: A non-statistical sample of 4 ($291,493) out of 21 ($392,941) purchases / contracts with expenditures over the micropurchase threshold of $3,000 were tested for procurement. In addition, suspension and debarment was applicable to two vendors. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements. Views of Responsible Officials: Management agrees with the finding and the recommendation.