Audit 7999

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-003 – Major Federal Award Finding – Reporting Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year finding #2022-003. Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding these quarterly reports. In addition, some inaccuracies were noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process for the quarterly reports. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2022 calendar annual report for HEERF student disbursements and institutional expenditures. Recommendation: Management should review the University’s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2022 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will submit a revised report for the 2022 calendar year and will put a procedure in place to ensure that all reports are reviewed prior to submission. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-002 – Major Federal Award Finding – Procurement and Suspension and Debarment Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-002. Conditions: We noted during testing of procurement for the HEERF program (Institutional Aid) that the University’s procurement policy was not being followed. Competitive bids were not obtained for projects over the simplified acquisition threshold. Criteria: Federal regulations 2 CFR Section 200.317- 200.326 provide that the University must have and use documented procurement procedures and follow written standards that promote full and open vendor competition. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in §200.320, depending upon the dollar value of the purchase or contract. Cause/Context: We tested two transactions over the micro purchase threshold. These transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations. We tested two transactions for a vendor over the simplified acquisition threshold. These transactions were not subject to the procurement processes required by the Uniform Guidance as it relates to price quotations and/or competitive bids. Recommendation: Management should review the University’s procurement policy and update appropriately to reference Uniform Guidance and specific purchasing thresholds. The University should ensure that it follows the requirements outlined in its procurement policy in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will review its current procurement policy to include federal regulations 2 CFR Section 200.317-200.326. Proper oversight will be provided over the procurement process. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-002 – Major Federal Award Finding – Procurement and Suspension and Debarment Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-002. Conditions: We noted during testing of procurement for the HEERF program (Institutional Aid) that the University’s procurement policy was not being followed. Competitive bids were not obtained for projects over the simplified acquisition threshold. Criteria: Federal regulations 2 CFR Section 200.317- 200.326 provide that the University must have and use documented procurement procedures and follow written standards that promote full and open vendor competition. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in §200.320, depending upon the dollar value of the purchase or contract. Cause/Context: We tested two transactions over the micro purchase threshold. These transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations. We tested two transactions for a vendor over the simplified acquisition threshold. These transactions were not subject to the procurement processes required by the Uniform Guidance as it relates to price quotations and/or competitive bids. Recommendation: Management should review the University’s procurement policy and update appropriately to reference Uniform Guidance and specific purchasing thresholds. The University should ensure that it follows the requirements outlined in its procurement policy in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will review its current procurement policy to include federal regulations 2 CFR Section 200.317-200.326. Proper oversight will be provided over the procurement process. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-003 – Major Federal Award Finding – Reporting Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year finding #2022-003. Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding these quarterly reports. In addition, some inaccuracies were noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process for the quarterly reports. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2022 calendar annual report for HEERF student disbursements and institutional expenditures. Recommendation: Management should review the University’s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2022 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will submit a revised report for the 2022 calendar year and will put a procedure in place to ensure that all reports are reviewed prior to submission. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-003 – Major Federal Award Finding – Reporting Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year finding #2022-003. Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding these quarterly reports. In addition, some inaccuracies were noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process for the quarterly reports. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2022 calendar annual report for HEERF student disbursements and institutional expenditures. Recommendation: Management should review the University’s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2022 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will submit a revised report for the 2022 calendar year and will put a procedure in place to ensure that all reports are reviewed prior to submission. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-002 – Major Federal Award Finding – Procurement and Suspension and Debarment Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-002. Conditions: We noted during testing of procurement for the HEERF program (Institutional Aid) that the University’s procurement policy was not being followed. Competitive bids were not obtained for projects over the simplified acquisition threshold. Criteria: Federal regulations 2 CFR Section 200.317- 200.326 provide that the University must have and use documented procurement procedures and follow written standards that promote full and open vendor competition. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in §200.320, depending upon the dollar value of the purchase or contract. Cause/Context: We tested two transactions over the micro purchase threshold. These transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations. We tested two transactions for a vendor over the simplified acquisition threshold. These transactions were not subject to the procurement processes required by the Uniform Guidance as it relates to price quotations and/or competitive bids. Recommendation: Management should review the University’s procurement policy and update appropriately to reference Uniform Guidance and specific purchasing thresholds. The University should ensure that it follows the requirements outlined in its procurement policy in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will review its current procurement policy to include federal regulations 2 CFR Section 200.317-200.326. Proper oversight will be provided over the procurement process. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-002 – Major Federal Award Finding – Procurement and Suspension and Debarment Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-002. Conditions: We noted during testing of procurement for the HEERF program (Institutional Aid) that the University’s procurement policy was not being followed. Competitive bids were not obtained for projects over the simplified acquisition threshold. Criteria: Federal regulations 2 CFR Section 200.317- 200.326 provide that the University must have and use documented procurement procedures and follow written standards that promote full and open vendor competition. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in §200.320, depending upon the dollar value of the purchase or contract. Cause/Context: We tested two transactions over the micro purchase threshold. These transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations. We tested two transactions for a vendor over the simplified acquisition threshold. These transactions were not subject to the procurement processes required by the Uniform Guidance as it relates to price quotations and/or competitive bids. Recommendation: Management should review the University’s procurement policy and update appropriately to reference Uniform Guidance and specific purchasing thresholds. The University should ensure that it follows the requirements outlined in its procurement policy in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will review its current procurement policy to include federal regulations 2 CFR Section 200.317-200.326. Proper oversight will be provided over the procurement process. See also attached Corrective Action Plan.

Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-003 – Major Federal Award Finding – Reporting Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year finding #2022-003. Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding these quarterly reports. In addition, some inaccuracies were noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process for the quarterly reports. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2022 calendar annual report for HEERF student disbursements and institutional expenditures. Recommendation: Management should review the University’s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2022 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will submit a revised report for the 2022 calendar year and will put a procedure in place to ensure that all reports are reviewed prior to submission. See also attached Corrective Action Plan.