Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion 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 the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion 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 the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Finding No. 2022-002 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). For those procurements supported by HEERF grant funds, auditors should determine if institutions sufficiently documented rationales and determinations in making any sole source awards during the time of national emergency due to the coronavirus. Exceptions from the competitive procurement requirements of the Uniform Guidance may be accepted if institutions have documented that the public exigency or emergency would not permit a delay, in accordance with 2 CFR section 200.320(f)(2). A circumstance that may influence this determination is the length of time between the procurements and the emergency at issue. Specifically, exceptions are more likely to be acceptable the closer the procurement occurred to the March 13, 2020 declaration of the national emergency. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University?s procurement policy for procurements over $10,000 is to either competitively bid it or document the sole source justification for why competitive bidding was not able to be completed. Based on our test work, for two of our seven selections, the University did not properly document its compliance with the procurement policy. For one selection, we noted that the University did not properly retain documentation for the competitive bidding, while for the other selection, the University did not properly document within the vendor?s procurement file that it was sole sourced due to the pandemic and needing the services in an expedited fashion as allowed per the HEERF requirements. Cause The documentation of procurement decisions was not properly retained to support the decisions made during the time period. Effect The University was not in compliance with their procurement policy. Questioned Costs There were no questioned costs identified as the University contracted with the respective parties in both cases and the costs were allowable under the HEERF requirements. Recommendation The University should strengthen its policies and practices to ensure that documentation is retained for all procurement decisions in order to support compliance with their procurement policy. Views of Responsible Official Management agrees with the recommendation. The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy.
Finding No. 2022-003 Research and Development Cluster: U.S. Department of Defense: Improved Ventilation of the Edematous Lung, Assistance Listing 93.838 (award number: 1R01HL113577-01A1) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-002). Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number. We selected twenty-five pieces of equipment and noted for one selection, the asset?s tag was not included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management did not properly ensure that the tag number was included within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Stevens Kuali Financial System. The Division of Finance has instituted an additional procedure to generate monthly asset tagging reports to address this issue and ensure that all assets are tagged in a timely manner. In addition, the Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System.
Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion 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 the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion 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 the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Finding No. 2022-002 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). For those procurements supported by HEERF grant funds, auditors should determine if institutions sufficiently documented rationales and determinations in making any sole source awards during the time of national emergency due to the coronavirus. Exceptions from the competitive procurement requirements of the Uniform Guidance may be accepted if institutions have documented that the public exigency or emergency would not permit a delay, in accordance with 2 CFR section 200.320(f)(2). A circumstance that may influence this determination is the length of time between the procurements and the emergency at issue. Specifically, exceptions are more likely to be acceptable the closer the procurement occurred to the March 13, 2020 declaration of the national emergency. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University?s procurement policy for procurements over $10,000 is to either competitively bid it or document the sole source justification for why competitive bidding was not able to be completed. Based on our test work, for two of our seven selections, the University did not properly document its compliance with the procurement policy. For one selection, we noted that the University did not properly retain documentation for the competitive bidding, while for the other selection, the University did not properly document within the vendor?s procurement file that it was sole sourced due to the pandemic and needing the services in an expedited fashion as allowed per the HEERF requirements. Cause The documentation of procurement decisions was not properly retained to support the decisions made during the time period. Effect The University was not in compliance with their procurement policy. Questioned Costs There were no questioned costs identified as the University contracted with the respective parties in both cases and the costs were allowable under the HEERF requirements. Recommendation The University should strengthen its policies and practices to ensure that documentation is retained for all procurement decisions in order to support compliance with their procurement policy. Views of Responsible Official Management agrees with the recommendation. The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy.
Finding No. 2022-003 Research and Development Cluster: U.S. Department of Defense: Improved Ventilation of the Edematous Lung, Assistance Listing 93.838 (award number: 1R01HL113577-01A1) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-002). Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number. We selected twenty-five pieces of equipment and noted for one selection, the asset?s tag was not included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management did not properly ensure that the tag number was included within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Stevens Kuali Financial System. The Division of Finance has instituted an additional procedure to generate monthly asset tagging reports to address this issue and ensure that all assets are tagged in a timely manner. In addition, the Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System.