Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.