Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-005 – Material Weakness: Equipment and Real Property Management – Compliance and Control Finding
ALN 84.031 – Title III – Higher Education – Institutional Aid
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000:
• Equipment must be used in the program for which it was acquired;
• Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property;
• A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years;
• A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property;
• Adequate maintenance procedures must be developed to keep the property in good condition.
In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements.
Condition: The University does not have a process in place to ensure federally funded equipment is subjected to a physical inventory observation at least once every two years.
Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements.
Effect: Instances of noncompliance were not detected by management.
Questioned Costs: Not applicable.
Context: Based on a sample of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds prior to 2022 has not been completed within the last two years.
Identification As A Repeat Finding: 2022-011 and 2021-017
Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory observation for all equipment purchased with grant funding.
Views Of Responsible Officials: The University has implemented guidelines for categorizing equipment and supplies. Additionally, HSSU is presently exploring an Asset Management software solution to facilitate inventory tracking and intends to carry out biannual inventory audits.
Finding 2023-005 – Material Weakness: Equipment and Real Property Management – Compliance and Control Finding
ALN 84.031 – Title III – Higher Education – Institutional Aid
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000:
• Equipment must be used in the program for which it was acquired;
• Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property;
• A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years;
• A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property;
• Adequate maintenance procedures must be developed to keep the property in good condition.
In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements.
Condition: The University does not have a process in place to ensure federally funded equipment is subjected to a physical inventory observation at least once every two years.
Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements.
Effect: Instances of noncompliance were not detected by management.
Questioned Costs: Not applicable.
Context: Based on a sample of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds prior to 2022 has not been completed within the last two years.
Identification As A Repeat Finding: 2022-011 and 2021-017
Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory observation for all equipment purchased with grant funding.
Views Of Responsible Officials: The University has implemented guidelines for categorizing equipment and supplies. Additionally, HSSU is presently exploring an Asset Management software solution to facilitate inventory tracking and intends to carry out biannual inventory audits.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).
Finding 2023-005 – Material Weakness: Equipment and Real Property Management – Compliance and Control Finding
ALN 84.031 – Title III – Higher Education – Institutional Aid
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000:
• Equipment must be used in the program for which it was acquired;
• Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property;
• A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years;
• A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property;
• Adequate maintenance procedures must be developed to keep the property in good condition.
In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements.
Condition: The University does not have a process in place to ensure federally funded equipment is subjected to a physical inventory observation at least once every two years.
Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements.
Effect: Instances of noncompliance were not detected by management.
Questioned Costs: Not applicable.
Context: Based on a sample of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds prior to 2022 has not been completed within the last two years.
Identification As A Repeat Finding: 2022-011 and 2021-017
Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory observation for all equipment purchased with grant funding.
Views Of Responsible Officials: The University has implemented guidelines for categorizing equipment and supplies. Additionally, HSSU is presently exploring an Asset Management software solution to facilitate inventory tracking and intends to carry out biannual inventory audits.
Finding 2023-005 – Material Weakness: Equipment and Real Property Management – Compliance and Control Finding
ALN 84.031 – Title III – Higher Education – Institutional Aid
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000:
• Equipment must be used in the program for which it was acquired;
• Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property;
• A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years;
• A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property;
• Adequate maintenance procedures must be developed to keep the property in good condition.
In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements.
Condition: The University does not have a process in place to ensure federally funded equipment is subjected to a physical inventory observation at least once every two years.
Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements.
Effect: Instances of noncompliance were not detected by management.
Questioned Costs: Not applicable.
Context: Based on a sample of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds prior to 2022 has not been completed within the last two years.
Identification As A Repeat Finding: 2022-011 and 2021-017
Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory observation for all equipment purchased with grant funding.
Views Of Responsible Officials: The University has implemented guidelines for categorizing equipment and supplies. Additionally, HSSU is presently exploring an Asset Management software solution to facilitate inventory tracking and intends to carry out biannual inventory audits.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.
Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding
ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days.
Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting.
Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring.
Questioned Costs: None.
Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program.
Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).