2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.