Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-011 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check, inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-011 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check, inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-007 ? Material Weakness: Allowable Costs & Activities and Period of Performance? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) section 314(c )(1-3) notes that HEERF Institutional Portion funds are to be used to defray expenses associated with coronavirus or to carry out student support activities that address needs related to coronavirus. 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $766,177 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 23 individual costs charged to the grant, 4 items tested, all payroll related, did not include adequate documentation. For the payroll items, the University did not provide documentation to support the time and effort of each student worker charged to the grant. For a sample of 23 individual costs charged to the grant, 7 items tested were utilized to cover costs related to building renovations and the associated project management. The documentation provided did not indicate that these costs were utilized to defray expenses associated with coronavirus. The control over compliance to ensure costs charged to the grant were allowable did not operate effectively. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-010 Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. In addition, we recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-009 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not provide proof that the quarterly reports for the Institutional Portion were posted to its website by required date. In addition, the University did not provide supporting documentation that a second review to verify that the information on the quarterly Institutional Portion reports and the Annual Report was accurate and that the reports were filed timely. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2021-013 and 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored, required information is communicated and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-010 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425E ? Higher Education Emergency Relief Fund (HEERF) Students Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Student Aid funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not report any HEERF Student Aid costs for fiscal year 2022. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public sufficient information regarding the spending of HEERF Student Aid that would allow the public to understand the proper amount and nature of its use of HEERF Student Aid funds. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: Not applicable. Context: The University did not report any HEERF Student Aid costs for fiscal year 2022. The University was not aware of the requirements to report the student portion costs. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-014 and 2020-011. Recommendation: We recommend that management implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-008 ? Material Weakness: Allowable Costs and Activities and Period of Performance ? Control Finding ALN 84.425J ? Higher Education Emergency Relief Fund (HEERF) HBCU Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is allowed to utilize HEERF funding to reimburse lost revenues associated with room and board and childcare services. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The University did not provide supporting documentation that a second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: None noted Context: During the testing performed, it was noted that HEERF funds were utilized to reimburse the University for lost revenues. There was no control identified to ensure costs charged to the grant were allowable and incurred within the period of performance. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-011 and 2020-009. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University will document lost revenue in comparison to the Board of Regents approved budget. The calculation will be prepared by the Assistant Comptroller, reviewed by the Comptroller as the second reviewer, and approved by the Chief Financial Officer, as the third and final review for charges being allocated to the grant.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-009 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not provide proof that the quarterly reports for the Institutional Portion were posted to its website by required date. In addition, the University did not provide supporting documentation that a second review to verify that the information on the quarterly Institutional Portion reports and the Annual Report was accurate and that the reports were filed timely. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2021-013 and 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored, required information is communicated and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-011 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check, inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-011 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check, inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.
Finding 2022-007 ? Material Weakness: Allowable Costs & Activities and Period of Performance? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) section 314(c )(1-3) notes that HEERF Institutional Portion funds are to be used to defray expenses associated with coronavirus or to carry out student support activities that address needs related to coronavirus. 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $766,177 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 23 individual costs charged to the grant, 4 items tested, all payroll related, did not include adequate documentation. For the payroll items, the University did not provide documentation to support the time and effort of each student worker charged to the grant. For a sample of 23 individual costs charged to the grant, 7 items tested were utilized to cover costs related to building renovations and the associated project management. The documentation provided did not indicate that these costs were utilized to defray expenses associated with coronavirus. The control over compliance to ensure costs charged to the grant were allowable did not operate effectively. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-010 Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. In addition, we recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-009 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not provide proof that the quarterly reports for the Institutional Portion were posted to its website by required date. In addition, the University did not provide supporting documentation that a second review to verify that the information on the quarterly Institutional Portion reports and the Annual Report was accurate and that the reports were filed timely. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2021-013 and 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored, required information is communicated and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-010 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425E ? Higher Education Emergency Relief Fund (HEERF) Students Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Student Aid funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not report any HEERF Student Aid costs for fiscal year 2022. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public sufficient information regarding the spending of HEERF Student Aid that would allow the public to understand the proper amount and nature of its use of HEERF Student Aid funds. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: Not applicable. Context: The University did not report any HEERF Student Aid costs for fiscal year 2022. The University was not aware of the requirements to report the student portion costs. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-014 and 2020-011. Recommendation: We recommend that management implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-008 ? Material Weakness: Allowable Costs and Activities and Period of Performance ? Control Finding ALN 84.425J ? Higher Education Emergency Relief Fund (HEERF) HBCU Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is allowed to utilize HEERF funding to reimburse lost revenues associated with room and board and childcare services. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The University did not provide supporting documentation that a second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: None noted Context: During the testing performed, it was noted that HEERF funds were utilized to reimburse the University for lost revenues. There was no control identified to ensure costs charged to the grant were allowable and incurred within the period of performance. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-011 and 2020-009. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University will document lost revenue in comparison to the Board of Regents approved budget. The calculation will be prepared by the Assistant Comptroller, reviewed by the Comptroller as the second reviewer, and approved by the Chief Financial Officer, as the third and final review for charges being allocated to the grant.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-009 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not provide proof that the quarterly reports for the Institutional Portion were posted to its website by required date. In addition, the University did not provide supporting documentation that a second review to verify that the information on the quarterly Institutional Portion reports and the Annual Report was accurate and that the reports were filed timely. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2021-013 and 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored, required information is communicated and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.
Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.
Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::