Noncompliance with 10-Day Rule (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University may not disburse funds to a student more than 10 days before the start of a semester. Condition. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. Cause. The University lacks a review process to ensure the timing of funds distributed to students is in accordance with federal guidelines. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Miscalculation of Student Cost of Attendance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University must accurately estimate the cost to attend the university for the fiscal year. Condition. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. Cause. The University lacks a review process to ensure student budgets are locked upon initial packaging and cannot be modified without appropriate review and approval. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked after initial packaging and no changes made without proper review and approval. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Lack of Review over Financial Status Reports Finding Type. Significant Deficiency in Internal Control over Compliance (Cash Management and Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Per 2 CFR §200.305(b), non-federal entities must minimize the time elapsing between the transfer of funds and disbursement, and also must maintain accurate financial records and submit required Federal Financial Status Reports ("FSR"). Entities must also ensure that drawdowns and FSRs are complete, based on actual, allowable expenditures, supported by underlying accounting records, and prepared in accordance with Federal requirements. Condition. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. Cause. The University lacked formal internal controls and oversight mechanisms to ensure drawdowns and FSRs were reviewed prior to submission. The process relied on informal practices without documented policies or designated reviewers. Effect. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. The University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Untimely Submission of Financial Status Reports (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Financial Status Reports must be submitted to the Department's EGrAMS website on a monthly basis, no later than 30 days after the close of each calendar month. Condition. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. Cause. The University lacks a review process to ensure the Financial Status Reports are submitted within the submission period. Effect. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Non-Compliance with Servicer to Deliver Title IV Credit Balances Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.164(e), institutions that enter into Tier Two Arrangements must maintain a written agreement with the financial institution, disclose the agreement publicly on the institution's website, conduct and document a free biennial review, report the arrangement to Federal Student Aid, and implement internal controls to ensure compliance. Condition. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Cause. The University has not developed or implemented formal compliance procedures for Tier Two Arrangement requirements. Effect. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2025-009 – Insufficient Supporting Documentation of Disbursements Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.403(g) and 2 CFR 200.334, federal award expenses must be adequately documented, and records must be retained and available for review for the required retention period. Condition. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. Cause. The lack of required supporting documentation resulted from employee turnover within the grant and accounts payable functions, which led to gaps in knowledge transfer and inconsistent adherence to established documentation procedures. Effect. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. There were questioned costs of $135. Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2025-010 – Indirect Cost Rate Review Finding Type. Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.400(e), when reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, the cognizant agency for indirect costs should ensure that the recipient consistently applies these cost principles. Condition. The University does not have a formal review process related to indirect cost rate automated entries. Cause. The University has not developed or implemented formal review procedures related to indirect costs. Effect. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Incorrect Term Dates Used in R2T4 Calculations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.22, institutions are required to calculate the percentage of Title IV aid earned based on the number of calendar days completed in the payment period or period of enrollment, beginning with the actual first day of the term as defined by the institution’s academic calendar. Condition. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. Cause. Controls were not in place to ensure the term start date used in R2T4 calculations was verified against the academic calendar prior to processing. Effect. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Questioned Costs. There were questioned costs of $96. Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.