Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 13 MONROE-GREGG SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 13 MONROE-GREGG SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 13 MONROE-GREGG SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 13 MONROE-GREGG SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 13 MONROE-GREGG SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Controls over Allowable Costs Federal agency: Florida Department of Education Federal program titles: Title 1 Grants for Local Education Agencies, Education Stabilization Fund Federal Award Identification Number and Year: 530-2122B-2CB01, 530,1211A-2C001, 530-1211D- 2CR01, 530-1211G-2CR01, 530-1211H-2CR01, 530-1211M-2CR01, 530-1211R-2CR01, 530-1211T- 3CR01, 530-1230A-1C001, 530-1230B-1CS01, 530-1230F-1C001, 530-1240A-1C001, 530-1240C- 1C001, 530-1240F-1C001, 530-1240S-1C001, 530-1241B-1CR01, 530-1241C-1CR01, 530-1241D- 1CR01, 530-1241E-1CR01, 530-1241P-2C001, 530-1241V-2CR01, 530-1281E-2C001, 530-1281N- 3CR01 Assistance Listing Numbers: 84.010, 84.425 (E, F, C, D, U) Award Period: July 2021 through June 2022 & July 2021 through September 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over its federal awards. To ensure charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel who possess adequate knowledge and experience of program requirements. Condition: Certain supervisors are reviewing timecards for time and effort reporting as required by Uniform Guidance. Questioned costs: None Context: In a statistically valid sample of forty salary and benefit expenditures for Title 1, four records or 10% did not have supervisory approval. In a statistically valid sample of forty salary and benefit expenditures for Education Stabilization, five records or 12.5% did not have supervisory approval. Cause: The District did not maintain adequate supervisory approval of time and effort documentation. Effect: Without supervisory approval, the potential exists that payroll and benefit costs could be improperly charged to a grant. Repeat Finding: Yes, see 2021-002. Recommendation: We recommend a consistent timesheet approval process be used across the District to ensure all time and effort documentation is approved by a knowledgeable supervisor. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. (Continued) Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-053-PN01, 21611-053-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context The School Corporation is a member of the South LaPorte County Special Education Cooperative (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 20 NEW PRAIRIE UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-053-PN01 and 21611-053-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-053-PN01 and 21611-053-PN01 grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 NEW PRAIRIE UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-053-PN01, 21611-053-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context The School Corporation is a member of the South LaPorte County Special Education Cooperative (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 20 NEW PRAIRIE UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-053-PN01 and 21611-053-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-053-PN01 and 21611-053-PN01 grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 NEW PRAIRIE UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Assistance Listings number and name 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award number and years P425F201546-20B, May 6, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement(s) Allowable costs/cost principles Questioned costs $4,249,864 Condition?Contrary to federal guidance and regulations and the District?s federal indirect cost agreement, the District overcharged $4,249,864 of indirect costs to its HEERF program?s institutional portion during fiscal year 2022. Specifically, the District charged a total of $4,301,518, but its federal indirect cost agreement allowed it to charge no more than $51,654 when correctly applying and calculating the agreement?s base and allocation, thus it overcharged nearly $4.25 million. These unallowed indirect costs comprised 64 percent of the program?s total federal award expenditures for fiscal year 2022. Effect?The District?s spending $4,249,864 more on indirect costs than allowed resulted in less monies available to spend on allowable program costs for addressing institutional and student needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll) and making additional financial grants to students. Also, the U.S. Department of Education may require the District to repay the misspent monies in accordance with Uniform Guidance requirements.1 Cause?The District?s administration reported to us that it misinterpreted its federal indirect cost agreement when applying and calculating its indirect cost base and allocation. Further, the District did not follow its procedures for receiving written confirmation from its grantor of its indirect cost calculation method. Criteria?District procedures require employees to follow what is stated in the grant award notice, and verify and receive written confirmation from its grantor of the calculation method when calculating indirect costs when calculating indirect costs (Yuma/La Paz Counties Community College District's Grants Desk Manual, Grant Indirect Costs). Additionally, federal guidance and regulations require the District to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program?s base expenditures.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The District?s administration should: 1. Follow written procedures for applying and calculating indirect costs to its federal programs, including following and correctly applying the award?s base rate and allocation, which is stated in its grant award notice, and verifying and receiving written confirmation from its grantor of its calculation method when charging indirect costs to federal programs. 2. Work with the U.S. Department of Education to resolve the $4,249,864 of unallowable costs it allocated to the federal program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR ?200.513[c]). Further, it requires that federal awarding agencies? management decisions clearly state whether the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR ?200.521). 2 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III?Frequently Asked Questions, Question 43. Retrieved 12/13/2022 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. Also, U.S. Office of Management and Budget. (2021). 2 CFR 200.414 and Appendix III to 2 CFR Part 200?Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 12/13/2022 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200#sg2.1.200_1411.sg11%22.
Assistance Listings number and name 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award number and years P425F201546-20B, May 6, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement(s) Allowable costs/cost principles Questioned costs $4,249,864 Condition?Contrary to federal guidance and regulations and the District?s federal indirect cost agreement, the District overcharged $4,249,864 of indirect costs to its HEERF program?s institutional portion during fiscal year 2022. Specifically, the District charged a total of $4,301,518, but its federal indirect cost agreement allowed it to charge no more than $51,654 when correctly applying and calculating the agreement?s base and allocation, thus it overcharged nearly $4.25 million. These unallowed indirect costs comprised 64 percent of the program?s total federal award expenditures for fiscal year 2022. Effect?The District?s spending $4,249,864 more on indirect costs than allowed resulted in less monies available to spend on allowable program costs for addressing institutional and student needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll) and making additional financial grants to students. Also, the U.S. Department of Education may require the District to repay the misspent monies in accordance with Uniform Guidance requirements.1 Cause?The District?s administration reported to us that it misinterpreted its federal indirect cost agreement when applying and calculating its indirect cost base and allocation. Further, the District did not follow its procedures for receiving written confirmation from its grantor of its indirect cost calculation method. Criteria?District procedures require employees to follow what is stated in the grant award notice, and verify and receive written confirmation from its grantor of the calculation method when calculating indirect costs when calculating indirect costs (Yuma/La Paz Counties Community College District's Grants Desk Manual, Grant Indirect Costs). Additionally, federal guidance and regulations require the District to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program?s base expenditures.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The District?s administration should: 1. Follow written procedures for applying and calculating indirect costs to its federal programs, including following and correctly applying the award?s base rate and allocation, which is stated in its grant award notice, and verifying and receiving written confirmation from its grantor of its calculation method when charging indirect costs to federal programs. 2. Work with the U.S. Department of Education to resolve the $4,249,864 of unallowable costs it allocated to the federal program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR ?200.513[c]). Further, it requires that federal awarding agencies? management decisions clearly state whether the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR ?200.521). 2 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III?Frequently Asked Questions, Question 43. Retrieved 12/13/2022 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. Also, U.S. Office of Management and Budget. (2021). 2 CFR 200.414 and Appendix III to 2 CFR Part 200?Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 12/13/2022 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200#sg2.1.200_1411.sg11%22.
Finding 2022-002: Internal control deficiency and noncompliance over program income requirements. Identification of the federal program: Assistance Listing Number 93.918: ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? COVID-19 ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? U.S. Department of Health and Human Services ? Federal award identification numbers and award years: o 5 H76HA00151-31-00 ? January 1, 2018 to December 31, 2021 o 6 H76HA00151-31-01 ? January 1, 2018 to December 31, 2021 o 2 H76HA00151-32-00 ? January 1, 2022 to December 31, 2024 o 6 H76HA00151-32-01 ? January 1, 2022 to December 31, 2024 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls states: ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.305(b)(5) Federal payment states: ?To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.328 Financial reporting states: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as appliable, when providing financial and performance reporting information.? The Ryan White HIV/AIDS Program and Program Income Policy Clarification Notice #15-03 states the following: ? Under the uniform administrative requirements, to the extent available, recipients and subrecipients must disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. ? Recipients are required to track and account for all program income in accordance with 45 CFR 75.302(b)(3). Recipients must report program income on their Federal Financial Report (FFRs). ? Documentation of program income and accounting for its receipt and utilization will be consistent across Parts, to the extent possible. o Parts C, D, and F are discretionary awards and have multi-year periods of performance: ? Parts C, D, and F recipients must account for program income and its use within their multi-year period of performance. ? In the final year of funding, program income received at the end of the period of performance will be expended prior to new grant funds awarded in the next competitive cycle, so long as the recipient receives such subsequent award. Condition: During our review over program income, we observed management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Effect or potential effect: We were unable to test program income compliance or internal controls. Questioned costs: Unknown. Context: During our review over program income, we obtained the annual financial report submitted. We observed the total federal share of program income earned incorrectly reported Ryan White HIV/AIDS Program Part A, B, C and cash receipts unrelated to the program. The reported balance was also reported based on a cash basis instead of the accrual method stated on the federal financial report. We were unable to test the amount reported on the federal financial report as the amount reported is a cumulative amount from January 1, 2018 onward and included cash receipts unrelated to the program. During our review over program income, we observed management did not track program income earned as compared to the actual expenditures incurred. We were unable to test that program income was disbursed prior to requesting additional cash payments. Identification as a repeat finding, if applicable: Yes ? Finding 2021-004. Recommendation: We recommend that management develop and implement internal controls to ensure accurate reporting in the federal financial report and tracking of program income earned as compared to the actual expenditures incurred. This will ensure program income is reported and tracked accurately. Views of responsible officials: The Ryan White Part C program project period ended December 31, 2021 and a new project period started January 1, 2022 with the first federal financial report due in April 2023. Starting with the new program year, Valleywise Health management will develop and implement internal controls to ensure that program income is accurately calculated and reported in the federal financial report.
Finding 2022-002: Internal control deficiency and noncompliance over program income requirements. Identification of the federal program: Assistance Listing Number 93.918: ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? COVID-19 ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? U.S. Department of Health and Human Services ? Federal award identification numbers and award years: o 5 H76HA00151-31-00 ? January 1, 2018 to December 31, 2021 o 6 H76HA00151-31-01 ? January 1, 2018 to December 31, 2021 o 2 H76HA00151-32-00 ? January 1, 2022 to December 31, 2024 o 6 H76HA00151-32-01 ? January 1, 2022 to December 31, 2024 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls states: ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.305(b)(5) Federal payment states: ?To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.328 Financial reporting states: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as appliable, when providing financial and performance reporting information.? The Ryan White HIV/AIDS Program and Program Income Policy Clarification Notice #15-03 states the following: ? Under the uniform administrative requirements, to the extent available, recipients and subrecipients must disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. ? Recipients are required to track and account for all program income in accordance with 45 CFR 75.302(b)(3). Recipients must report program income on their Federal Financial Report (FFRs). ? Documentation of program income and accounting for its receipt and utilization will be consistent across Parts, to the extent possible. o Parts C, D, and F are discretionary awards and have multi-year periods of performance: ? Parts C, D, and F recipients must account for program income and its use within their multi-year period of performance. ? In the final year of funding, program income received at the end of the period of performance will be expended prior to new grant funds awarded in the next competitive cycle, so long as the recipient receives such subsequent award. Condition: During our review over program income, we observed management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Effect or potential effect: We were unable to test program income compliance or internal controls. Questioned costs: Unknown. Context: During our review over program income, we obtained the annual financial report submitted. We observed the total federal share of program income earned incorrectly reported Ryan White HIV/AIDS Program Part A, B, C and cash receipts unrelated to the program. The reported balance was also reported based on a cash basis instead of the accrual method stated on the federal financial report. We were unable to test the amount reported on the federal financial report as the amount reported is a cumulative amount from January 1, 2018 onward and included cash receipts unrelated to the program. During our review over program income, we observed management did not track program income earned as compared to the actual expenditures incurred. We were unable to test that program income was disbursed prior to requesting additional cash payments. Identification as a repeat finding, if applicable: Yes ? Finding 2021-004. Recommendation: We recommend that management develop and implement internal controls to ensure accurate reporting in the federal financial report and tracking of program income earned as compared to the actual expenditures incurred. This will ensure program income is reported and tracked accurately. Views of responsible officials: The Ryan White Part C program project period ended December 31, 2021 and a new project period started January 1, 2022 with the first federal financial report due in April 2023. Starting with the new program year, Valleywise Health management will develop and implement internal controls to ensure that program income is accurately calculated and reported in the federal financial report.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure accurate information was presented in order to be in compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $120 of known questioned costs identified. Context: We noted that for two claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by four meals and breakfast by one meal and in April 2022, the School Corporation had overclaimed breakfast by 358 meals and underclaimed lunches by 182 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement for purchases made outside of the purchasing cooperative. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If the vendor that was used outside of the purchasing cooperative would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure accurate information was presented in order to be in compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $120 of known questioned costs identified. Context: We noted that for two claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by four meals and breakfast by one meal and in April 2022, the School Corporation had overclaimed breakfast by 358 meals and underclaimed lunches by 182 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement for purchases made outside of the purchasing cooperative. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If the vendor that was used outside of the purchasing cooperative would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure accurate information was presented in order to be in compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $120 of known questioned costs identified. Context: We noted that for two claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by four meals and breakfast by one meal and in April 2022, the School Corporation had overclaimed breakfast by 358 meals and underclaimed lunches by 182 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement for purchases made outside of the purchasing cooperative. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If the vendor that was used outside of the purchasing cooperative would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure accurate information was presented in order to be in compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $120 of known questioned costs identified. Context: We noted that for two claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by four meals and breakfast by one meal and in April 2022, the School Corporation had overclaimed breakfast by 358 meals and underclaimed lunches by 182 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement for purchases made outside of the purchasing cooperative. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If the vendor that was used outside of the purchasing cooperative would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022 002: Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Director of National Intelligence (USDNI) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) U.S. Environmental Protection Agency (USEPA) U.S. Department of Energy (USDOE) U.S. Department of Education (USDE) Smithsonian Institution U.S. Department of Health and Human Services (USDHHS) Corporation for National and Community Service All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($482,298,931) Federal Award Numbers: Various ? See schedule of award numbers Federal Award Year: Various ? See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Condition Found: The University did not consistently follow its property management policies and procedures related to equipment purchased with federal funding from the Research and Development (R&D) Cluster program. The University conducts research at multiple locations throughout their campus, where equipment purchased with federal funds is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number that funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. During our physical observation of 60 pieces of equipment purchased with R&D Cluster funds (with a total cost value of $1,542,384), we noted the following: - Nine items (with a total cost value of $200,035) did not have property management tags affixed at the time of our observation. - Eight items (with a total cost value of $103,583) had property management tags with asset numbers that were inconsistent with the equipment listing. Upon further review, we noted the property management records contained a temporary asset tag number that had not been updated for the permanent tag subsequently affixed by department personnel. Further, we noted adequate management review controls had not been established to ensure property management records were accurately updated and equipment was properly tagged. The net book value of equipment related to the R&D Cluster program totaled $217,101,257 at June 30, 2022. Criteria: According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause: In discussing these conditions with University officials, they stated the University?s procedures for tagging equipment were delayed because the University?s personnel operated in a remote environment during fiscal years 2021 and 2022. Additionally, physical inventory procedures, which are designed detect differences between perpetual and actual information, were waived during fiscal years 2020 and 2021 as a result of the pandemic. Possible Asserted Effect: Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. We also recommend the University properly tag equipment in accordance with its policy. Views of University Officials: The University agrees with the finding. All departments of the University will be reminded that tagging is an integral part of the internal control process for capital assets and training will be made available before June 30, 2023.
Finding 2022 002: Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Director of National Intelligence (USDNI) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) U.S. Environmental Protection Agency (USEPA) U.S. Department of Energy (USDOE) U.S. Department of Education (USDE) Smithsonian Institution U.S. Department of Health and Human Services (USDHHS) Corporation for National and Community Service All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($482,298,931) Federal Award Numbers: Various ? See schedule of award numbers Federal Award Year: Various ? See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Condition Found: The University did not consistently follow its property management policies and procedures related to equipment purchased with federal funding from the Research and Development (R&D) Cluster program. The University conducts research at multiple locations throughout their campus, where equipment purchased with federal funds is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number that funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. During our physical observation of 60 pieces of equipment purchased with R&D Cluster funds (with a total cost value of $1,542,384), we noted the following: - Nine items (with a total cost value of $200,035) did not have property management tags affixed at the time of our observation. - Eight items (with a total cost value of $103,583) had property management tags with asset numbers that were inconsistent with the equipment listing. Upon further review, we noted the property management records contained a temporary asset tag number that had not been updated for the permanent tag subsequently affixed by department personnel. Further, we noted adequate management review controls had not been established to ensure property management records were accurately updated and equipment was properly tagged. The net book value of equipment related to the R&D Cluster program totaled $217,101,257 at June 30, 2022. Criteria: According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause: In discussing these conditions with University officials, they stated the University?s procedures for tagging equipment were delayed because the University?s personnel operated in a remote environment during fiscal years 2021 and 2022. Additionally, physical inventory procedures, which are designed detect differences between perpetual and actual information, were waived during fiscal years 2020 and 2021 as a result of the pandemic. Possible Asserted Effect: Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. We also recommend the University properly tag equipment in accordance with its policy. Views of University Officials: The University agrees with the finding. All departments of the University will be reminded that tagging is an integral part of the internal control process for capital assets and training will be made available before June 30, 2023.
Finding 2022 002: Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Director of National Intelligence (USDNI) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) U.S. Environmental Protection Agency (USEPA) U.S. Department of Energy (USDOE) U.S. Department of Education (USDE) Smithsonian Institution U.S. Department of Health and Human Services (USDHHS) Corporation for National and Community Service All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($482,298,931) Federal Award Numbers: Various ? See schedule of award numbers Federal Award Year: Various ? See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Condition Found: The University did not consistently follow its property management policies and procedures related to equipment purchased with federal funding from the Research and Development (R&D) Cluster program. The University conducts research at multiple locations throughout their campus, where equipment purchased with federal funds is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number that funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. During our physical observation of 60 pieces of equipment purchased with R&D Cluster funds (with a total cost value of $1,542,384), we noted the following: - Nine items (with a total cost value of $200,035) did not have property management tags affixed at the time of our observation. - Eight items (with a total cost value of $103,583) had property management tags with asset numbers that were inconsistent with the equipment listing. Upon further review, we noted the property management records contained a temporary asset tag number that had not been updated for the permanent tag subsequently affixed by department personnel. Further, we noted adequate management review controls had not been established to ensure property management records were accurately updated and equipment was properly tagged. The net book value of equipment related to the R&D Cluster program totaled $217,101,257 at June 30, 2022. Criteria: According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause: In discussing these conditions with University officials, they stated the University?s procedures for tagging equipment were delayed because the University?s personnel operated in a remote environment during fiscal years 2021 and 2022. Additionally, physical inventory procedures, which are designed detect differences between perpetual and actual information, were waived during fiscal years 2020 and 2021 as a result of the pandemic. Possible Asserted Effect: Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. We also recommend the University properly tag equipment in accordance with its policy. Views of University Officials: The University agrees with the finding. All departments of the University will be reminded that tagging is an integral part of the internal control process for capital assets and training will be made available before June 30, 2023.
Finding 2022 002: Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Director of National Intelligence (USDNI) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) U.S. Environmental Protection Agency (USEPA) U.S. Department of Energy (USDOE) U.S. Department of Education (USDE) Smithsonian Institution U.S. Department of Health and Human Services (USDHHS) Corporation for National and Community Service All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($482,298,931) Federal Award Numbers: Various ? See schedule of award numbers Federal Award Year: Various ? See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Condition Found: The University did not consistently follow its property management policies and procedures related to equipment purchased with federal funding from the Research and Development (R&D) Cluster program. The University conducts research at multiple locations throughout their campus, where equipment purchased with federal funds is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number that funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. During our physical observation of 60 pieces of equipment purchased with R&D Cluster funds (with a total cost value of $1,542,384), we noted the following: - Nine items (with a total cost value of $200,035) did not have property management tags affixed at the time of our observation. - Eight items (with a total cost value of $103,583) had property management tags with asset numbers that were inconsistent with the equipment listing. Upon further review, we noted the property management records contained a temporary asset tag number that had not been updated for the permanent tag subsequently affixed by department personnel. Further, we noted adequate management review controls had not been established to ensure property management records were accurately updated and equipment was properly tagged. The net book value of equipment related to the R&D Cluster program totaled $217,101,257 at June 30, 2022. Criteria: According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause: In discussing these conditions with University officials, they stated the University?s procedures for tagging equipment were delayed because the University?s personnel operated in a remote environment during fiscal years 2021 and 2022. Additionally, physical inventory procedures, which are designed detect differences between perpetual and actual information, were waived during fiscal years 2020 and 2021 as a result of the pandemic. Possible Asserted Effect: Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. We also recommend the University properly tag equipment in accordance with its policy. Views of University Officials: The University agrees with the finding. All departments of the University will be reminded that tagging is an integral part of the internal control process for capital assets and training will be made available before June 30, 2023.
Finding 2022 002: Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Director of National Intelligence (USDNI) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) U.S. Environmental Protection Agency (USEPA) U.S. Department of Energy (USDOE) U.S. Department of Education (USDE) Smithsonian Institution U.S. Department of Health and Human Services (USDHHS) Corporation for National and Community Service All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($482,298,931) Federal Award Numbers: Various ? See schedule of award numbers Federal Award Year: Various ? See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Condition Found: The University did not consistently follow its property management policies and procedures related to equipment purchased with federal funding from the Research and Development (R&D) Cluster program. The University conducts research at multiple locations throughout their campus, where equipment purchased with federal funds is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number that funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. During our physical observation of 60 pieces of equipment purchased with R&D Cluster funds (with a total cost value of $1,542,384), we noted the following: - Nine items (with a total cost value of $200,035) did not have property management tags affixed at the time of our observation. - Eight items (with a total cost value of $103,583) had property management tags with asset numbers that were inconsistent with the equipment listing. Upon further review, we noted the property management records contained a temporary asset tag number that had not been updated for the permanent tag subsequently affixed by department personnel. Further, we noted adequate management review controls had not been established to ensure property management records were accurately updated and equipment was properly tagged. The net book value of equipment related to the R&D Cluster program totaled $217,101,257 at June 30, 2022. Criteria: According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause: In discussing these conditions with University officials, they stated the University?s procedures for tagging equipment were delayed because the University?s personnel operated in a remote environment during fiscal years 2021 and 2022. Additionally, physical inventory procedures, which are designed detect differences between perpetual and actual information, were waived during fiscal years 2020 and 2021 as a result of the pandemic. Possible Asserted Effect: Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. We also recommend the University properly tag equipment in accordance with its policy. Views of University Officials: The University agrees with the finding. All departments of the University will be reminded that tagging is an integral part of the internal control process for capital assets and training will be made available before June 30, 2023.