Federal Agency: U.S. Department of Labor Federal Program: Disability Employment Policy Development Federal Award Number: 17.720 Federal Award Year: July 1, 2021 through June 30, 2022; July 1, 2022 through June 30, 2023 Compliance Requirement Allowable Costs (B), Cash Management (C) Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Program costs must be paid by non-federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)) (i.e., the non-federal entity must disburse funds for program purposes before requesting payment from the federal awarding agency or pass-through entity). Condition Found, Including Perspective For 3 out of 40 payroll samples tested, an internet stipend was charged twice to the program. The amount of the overcharge to the program was $120 and the total sampled payroll population was $98,294. For 1 out of 40 other than payroll samples, compensation for a training session was charged to the program that was not incurred by the entity. The amount of the overcharge to the program was $100 and the total other than payroll sampled population was $188,437. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct charges to the program that were duplicated or not incurred by the entity. Questioned Costs Questioned costs totaled $220. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the appropriateness of the expenses charged to the program. Views of Responsible Officials Management agrees with the findings and will implement a more detailed review process of the invoicing prior to submission. This review process will include a review of the expenditures being requested for reimbursement with no materiality threshold.
Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Number: 84.063 Federal Pell Grant Program and 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2021 through June 30, 2022 Compliance Requirement Special Tests and Provisions (N) ? Enrollment Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the Pell grant and direct loan programs, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the enrollment reporting roster file within 15 days of receipt. An institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, 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 National Student Loan Data System (NSLDS) website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The institution must report the status change in its next updated enrollment reporting roster file (due within 60 days of the change). Condition Found, Including Perspective During our procedures for enrollment reporting, we identified 2 out of 40 student samples from Mercy College of Ohio in which enrollment status changes were not reported to NSLDS within the timeframe required. Cause and Possible Asserted Effect Managements? control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify instances of student enrollments not being reported correctly on a timely basis. Questioned Costs There are no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its processes and control regarding the configuration and timing of enrollment reporting to the National Student Clearinghouse to ensure that all student status changes are communicated timely to NSLDS. Views of Responsible Officials Management agrees with the findings and recommendations. BSMH has developed controls around the timeliness of enrollment reporting as indicated in our Corrective Action Plan. BSMH?s enhanced processes and procedures includes additional safeguards around submissions to the National Student Loan Database Systems (NSLDS). The instances related to timeliness of reporting of certain students was due to an error in the data pulled from the Student Information System. The system failed to include newly registered spring 2022 students. BSMH makes note that this system failure was detected internally and corrected in the spring 2022 semester, prior to the independent audit of this program.
Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Number: 84.063 Federal Pell Grant Program and 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2021 through June 30, 2022 Compliance Requirement Special Tests and Provisions (N) ? Enrollment Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the Pell grant and direct loan programs, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the enrollment reporting roster file within 15 days of receipt. An institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, 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 National Student Loan Data System (NSLDS) website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The institution must report the status change in its next updated enrollment reporting roster file (due within 60 days of the change). Condition Found, Including Perspective During our procedures for enrollment reporting, we identified 2 out of 40 student samples from Mercy College of Ohio in which enrollment status changes were not reported to NSLDS within the timeframe required. Cause and Possible Asserted Effect Managements? control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify instances of student enrollments not being reported correctly on a timely basis. Questioned Costs There are no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its processes and control regarding the configuration and timing of enrollment reporting to the National Student Clearinghouse to ensure that all student status changes are communicated timely to NSLDS. Views of Responsible Officials Management agrees with the findings and recommendations. BSMH has developed controls around the timeliness of enrollment reporting as indicated in our Corrective Action Plan. BSMH?s enhanced processes and procedures includes additional safeguards around submissions to the National Student Loan Database Systems (NSLDS). The instances related to timeliness of reporting of certain students was due to an error in the data pulled from the Student Information System. The system failed to include newly registered spring 2022 students. BSMH makes note that this system failure was detected internally and corrected in the spring 2022 semester, prior to the independent audit of this program.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.
Federal Agency: U.S. Department of Labor Federal Program: Disability Employment Policy Development Federal Award Number: 17.720 Federal Award Year: July 1, 2021 through June 30, 2022; July 1, 2022 through June 30, 2023 Compliance Requirement Allowable Costs (B), Cash Management (C) Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Program costs must be paid by non-federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)) (i.e., the non-federal entity must disburse funds for program purposes before requesting payment from the federal awarding agency or pass-through entity). Condition Found, Including Perspective For 3 out of 40 payroll samples tested, an internet stipend was charged twice to the program. The amount of the overcharge to the program was $120 and the total sampled payroll population was $98,294. For 1 out of 40 other than payroll samples, compensation for a training session was charged to the program that was not incurred by the entity. The amount of the overcharge to the program was $100 and the total other than payroll sampled population was $188,437. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct charges to the program that were duplicated or not incurred by the entity. Questioned Costs Questioned costs totaled $220. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the appropriateness of the expenses charged to the program. Views of Responsible Officials Management agrees with the findings and will implement a more detailed review process of the invoicing prior to submission. This review process will include a review of the expenditures being requested for reimbursement with no materiality threshold.
Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Number: 84.063 Federal Pell Grant Program and 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2021 through June 30, 2022 Compliance Requirement Special Tests and Provisions (N) ? Enrollment Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the Pell grant and direct loan programs, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the enrollment reporting roster file within 15 days of receipt. An institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, 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 National Student Loan Data System (NSLDS) website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The institution must report the status change in its next updated enrollment reporting roster file (due within 60 days of the change). Condition Found, Including Perspective During our procedures for enrollment reporting, we identified 2 out of 40 student samples from Mercy College of Ohio in which enrollment status changes were not reported to NSLDS within the timeframe required. Cause and Possible Asserted Effect Managements? control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify instances of student enrollments not being reported correctly on a timely basis. Questioned Costs There are no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its processes and control regarding the configuration and timing of enrollment reporting to the National Student Clearinghouse to ensure that all student status changes are communicated timely to NSLDS. Views of Responsible Officials Management agrees with the findings and recommendations. BSMH has developed controls around the timeliness of enrollment reporting as indicated in our Corrective Action Plan. BSMH?s enhanced processes and procedures includes additional safeguards around submissions to the National Student Loan Database Systems (NSLDS). The instances related to timeliness of reporting of certain students was due to an error in the data pulled from the Student Information System. The system failed to include newly registered spring 2022 students. BSMH makes note that this system failure was detected internally and corrected in the spring 2022 semester, prior to the independent audit of this program.
Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Number: 84.063 Federal Pell Grant Program and 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2021 through June 30, 2022 Compliance Requirement Special Tests and Provisions (N) ? Enrollment Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the Pell grant and direct loan programs, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the enrollment reporting roster file within 15 days of receipt. An institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, 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 National Student Loan Data System (NSLDS) website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The institution must report the status change in its next updated enrollment reporting roster file (due within 60 days of the change). Condition Found, Including Perspective During our procedures for enrollment reporting, we identified 2 out of 40 student samples from Mercy College of Ohio in which enrollment status changes were not reported to NSLDS within the timeframe required. Cause and Possible Asserted Effect Managements? control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify instances of student enrollments not being reported correctly on a timely basis. Questioned Costs There are no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its processes and control regarding the configuration and timing of enrollment reporting to the National Student Clearinghouse to ensure that all student status changes are communicated timely to NSLDS. Views of Responsible Officials Management agrees with the findings and recommendations. BSMH has developed controls around the timeliness of enrollment reporting as indicated in our Corrective Action Plan. BSMH?s enhanced processes and procedures includes additional safeguards around submissions to the National Student Loan Database Systems (NSLDS). The instances related to timeliness of reporting of certain students was due to an error in the data pulled from the Student Information System. The system failed to include newly registered spring 2022 students. BSMH makes note that this system failure was detected internally and corrected in the spring 2022 semester, prior to the independent audit of this program.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.
Federal Agency: U.S. Department of Health and Human Services Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Number: 93.498 Federal Award Year: PRF reporting period 4 Compliance Requirement Reporting (L) ? Special Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain 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 the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. The Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements states that reporting entities that also received an ARP Rural payment must expend the ARP Rural funds on eligible expenses and/or lost revenues attributable to COVID-19 before PRF payments may be used on remining eligible expenses and/or lost revenues attributable to COVID-19. Condition Found, Including Perspective During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the Portal were correctly stated. Lost revenue is tracked by management at the system level and is allocated to various programs when reporting requirements require separate portal reporting. Management?s internal lost revenue calculation correctly captured all lost revenues, including reductions for ARP funds separately reported, and that calculation was appropriately attached to the Period 4 Portal submission. The Portal report has a cumulative calculation of available lost revenue, and the cumulative total calculation within the portal was not properly reduced to capture $15,518,774 that was separately claimed in ARP subsidiary Period 4 reports, resulting in an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues amounts in the Period 4 general distribution Portal report. Cause and Possible Asserted Effect Controls were not operating effectively to detect and correct duplicate lost revenues shown on the portal reporting between the parent entity and the stand-alone subsidiary reports for ARP funds. Although the lost revenues were calculated correctly and captured within the attached supporting documentation used to determine Portal amounts, controls were not operating effectively to detect and correct an overstatement of the Total Lost Revenues for the Period of Availability and the Total Unused Lost Revenues. Questioned Costs There are no questioned costs associated with this finding. Despite the overstatement in the Portal report, there was still sufficient lost revenues in excess of PRF payments received for Period 4 and therefore the Company has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendations We recommend that the Company enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that overstated lost revenue information is not reported. Views of Responsible Officials As indicated within the portal filing summary for the general reporting Period 4, the Company?s lost revenues exceeded PRF and ARP Rural payments received to-date. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF and ARP Rural funds received, regardless of the reporting error identified and described in the ?condition found? section above. Therefore, management believes no repayment of PRF or ARP Rural funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions.