Audit 405175

Program Student Financial Assistance (SFA) Cluster – Various ALNs Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. There are two categories of enrollment information “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting all Campus-Level Record and Program-Level Record data elements. Institutions are responsible for timely reporting. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. The institution must update for changes in the data elements for the Campus Record and the Program Record and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended,; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Out of a sample of 33 students, 4 had a status change that was not reported to the National Student Loan Data System (NSLDS). Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-003 (continued) Cause Processes and controls over the reporting of the student status change to the Department of Education are not properly designed or not functioning as intended to ensure that the University complies with this requirement. Effect The University did not comply with the enrollment reporting requirements, which may result in inaccurate or incomplete enrollment data in NSLDS and limit the Department of Education’s ability to monitor student eligibility and loan status. Questioned Costs Not applicable. Context We performed a test of detail where our statistically valid sample consisted of 33 items from a population of 221 students that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period. Based on the evidence examined, we noted 4 samples in which no reporting of enrollment data was provided to the National Student Loan Data System (NSLDS). Identification as a repeat finding, if applicable 2020-015 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.

Federal Program Education Stabilization Fund – ALN 84.425E, 84.425F, 84.425J, 84.425H Compliance Requirement Reporting Criteria The Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP) Act institutional quarterly reporting requirements involve publicly posting completed forms on the institution’s website. The forms must be conspicuously posted on the institution’s primary website on the same page as the reports of the Institution of Higher Education (IHE) activities related to the emergency financial aid grants to students (Student Aid Portion). A new, separate form must be posted covering aggregate amounts spent for Higher Education Emergency Relief Fund (HEERF I), HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all Institutional Portion funds and checks the “final report” box. IHEs must post this quarterly report no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). The Governors (Outlying Areas) reporting requirements involve a monthly report related to all expenditures of the issued award by the Government of the United States Virgin Islands. Condition Out of a sample of 10 performance and special reports, 5 were submitted past the established due date, and 4 were not submitted. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports. Effect The University did not comply with reporting requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-004 (continued) Context We performed a test of details using a statistically validated sample of 10 items selected from a population of 25 performance and special reports. Based on the evidence examined, we identified 5 samples in which reports were issued after the required submission deadline and 4 samples in which no reporting was provided to the direct recipient, the Government of the United States Virgin Islands. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.

Federal Program Smith Lever Extension – 10.511 Compliance Requirement Reporting Criteria Recipients must use the Federal Financial Report (FFR) as a standardized format to report expenditures under federal awards and submit them in a timely manner. Condition Two instances in which the control intended to ensure timely submission failed to prevent reports from being submitted after the due date. Cause Controls intended to ensure compliance with reporting timeliness requirements do not appear to be adequately designed or operating effectively. Effect Ineffective controls over the timely submission of FFRs increase the risk of delayed or incomplete reporting and may result in future noncompliance with federal reporting requirements. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-005 (continued) Context We performed a test of details to evaluate the timeliness of FFR submissions. Our sample consisted of 2 items, representing the full population of FFRs required to be submitted during the audit period. Based on the procedures performed, we identified 2 instances in which the reports were submitted after the required due date, with an average delay of approximately 33 days, indicating that controls over the timely submission of FFRs were not operating effectively. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.

Federal Program Small Business Development Centers – 59.037 Compliance Requirement Reporting Criteria Recipients must submit Performance Progress Reports using standard form PPR which includes a narrative statement that details all project accomplishments for the reporting period, including a comparison between actual accomplishments and those predicted in the project goals and milestones, and any lessons learned, best practices, notable success stories, problems encountered, and steps taken to address problems. Also, recipient must use the FFR as a standardized format to report expenditures under federal awards and submit them in a timely manner. Condition Out of a sample of 6 performance and special reports, 1 was submitted past the established due date, and 2 were not submitted. Out of a sample of 2 FFRs, 1 was submitted past the established due date. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports. Effect The University did not comply with reporting requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-006 (continued) Context We performed a test of details using a statistically validated sample of 6 items selected from a population of 8 performance and special reports, and a sample of 2 items selected from a population of 4 FFRs. Based on the evidence examined, we identified 2 samples in which reports were issued after the required submission deadline and 2 samples in which no report was submitted. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.

Federal Program Economic Adjustment Assistance - 11.307 Requirement Special Tests and Provisions – Wage Rate Requirements Criteria All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than the established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work was performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition Out of a sample of 6 construction contracts, none had the prevailing wage rates clause. Cause Processes and controls over the inclusion of the prevailing wage rates clause do not exist. Effect The University did not comply with the applicable wage rate requirements, leading to regulatory non-compliance. Questioned Costs Not applicable. Context We performed a test of detail where our statistically validated sample consisted of 6 items from a population of 6 construction contracts. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-007 (continued) Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University implements internal controls and procedures to ensure the prevailing wages rate clause is included in all applicable construction contracts. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.