Finding Reference Number: 2022-002 NH Department of Administrative Services Federal Transit Cluster and COVID-19 Federal Transit Cluster (Assistance Listing #20.507and #20.526) Airport Improvement Program and COVID-19 Airport Improvement Program (Assistance Listing #20.106) COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers 2020G996115, 2021G996115, SLFRP0145, NUK50CK000522, 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2019, 2020, 2021 U.S. Department of Transportation, U.S. Department of Treasury, U.S. Department of Health and Human Services Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition The State of New Hampshire (the State) entered into contracts and subrecipient grant agreements to assist with the administration of its federal awards. As part of the Schedule of Expenditures of Federal Awards (SEFA) preparation process, the Department of Administrative Services requested information from each Department related to federal expenditures made by federal program and the portion of those expenditures that were passed through to subrecipients. For the year ended June 30, 2022, the State reported approximately $3.5 billion in federal expenditures on the SEFA. Of the total expenditures reported, approximately $783 million was reported as amounts passed through to subrecipients. During our audit, we identified several instances where the State inaccurately reported the value of the amounts passed through to subrecipients for certain federal programs. Specifically, we noted the following: A. Federal Transit Cluster - The State reported subrecipient expenditures in the amount of $4,038,163 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over procurement, we noted that 1 of 4 contracts selected for testwork was incorrectly identified as a contract. Upon further review and inquiry of management, the actual subrecipient expenditures for the year ended June 30, 2022 were $375,302, resulting in an overstatement of $3,662,861. This error was subsequently corrected on the final SEFA. B. Airport Improvement Program - The State reported subrecipient expenditures in the amount of $8,275,240 on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $8,168,301, resulting in an overstatement of $106,939. This error was subsequently corrected on the final SEFA. C. Coronavirus State and Local Fiscal Recovery Funds ? The State reported subrecipient expenditures in the amount of $7,435,217 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over subrecipient monitoring, we noted that for 5 of 10 subrecipients selected for testwork that the sample selection had been incorrectly identified as a subrecipient, resulting in an overstatement of $5,326,620. We further noted as part of our testwork over procurement, that 18 of 48 contracts selected for testwork had incorrectly been identified as a contract and instead of a subrecipient grant agreement. There were no expenditures associated with these agreements, and as a result, there was no impact on the amount reported on the SEFA within the amounts provided to subrecipients column. The error was subsequently corrected on the final SEFA to properly present $2,108,597 as passed through to subrecipient. D. Epidemiology and Laboratory Capacity for Infectious Diseases - The State reported subrecipient expenditures in the amount of $4,879,473 on the draft SEFA within the amounts provided to subrecipients column. During our testwork related to FFATA reporting, we noted that 1 of 4 items selected for testwork did not represent a tier-one award but instead was a contract. The impact on the amount reported on the SEFA within the amounts provided to subrecipients column was an overstatement of $8,400. The error was subsequently corrected on the final SEFA to properly present $4,871,073 as passed through to subrecipient. E. Temporary Assistance for Needy Families - The State did not report any subrecipient expenditures on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $3,307,974, resulting in an understatement of $3,307,974. This error was subsequently corrected on the final SEFA. Cause The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient to ensure the proper identification of subrecipients. Effect The effect of the condition found is that subrecipient expenditures were not accurately presented on the SEFA. Questioned Costs None. Recommendation We recommend that the State review its existing statewide internal controls over vendor versus subrecipient determination to ensure they are operating effectively to properly identify a vendor versus a subrecipient. This will ensure that the amounts presented as pass through as subrecipient expenditures on the SEFA are complete and accurate. Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services
Finding Reference Number: 2022-002 NH Department of Administrative Services Federal Transit Cluster and COVID-19 Federal Transit Cluster (Assistance Listing #20.507and #20.526) Airport Improvement Program and COVID-19 Airport Improvement Program (Assistance Listing #20.106) COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers 2020G996115, 2021G996115, SLFRP0145, NUK50CK000522, 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2019, 2020, 2021 U.S. Department of Transportation, U.S. Department of Treasury, U.S. Department of Health and Human Services Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition The State of New Hampshire (the State) entered into contracts and subrecipient grant agreements to assist with the administration of its federal awards. As part of the Schedule of Expenditures of Federal Awards (SEFA) preparation process, the Department of Administrative Services requested information from each Department related to federal expenditures made by federal program and the portion of those expenditures that were passed through to subrecipients. For the year ended June 30, 2022, the State reported approximately $3.5 billion in federal expenditures on the SEFA. Of the total expenditures reported, approximately $783 million was reported as amounts passed through to subrecipients. During our audit, we identified several instances where the State inaccurately reported the value of the amounts passed through to subrecipients for certain federal programs. Specifically, we noted the following: A. Federal Transit Cluster - The State reported subrecipient expenditures in the amount of $4,038,163 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over procurement, we noted that 1 of 4 contracts selected for testwork was incorrectly identified as a contract. Upon further review and inquiry of management, the actual subrecipient expenditures for the year ended June 30, 2022 were $375,302, resulting in an overstatement of $3,662,861. This error was subsequently corrected on the final SEFA. B. Airport Improvement Program - The State reported subrecipient expenditures in the amount of $8,275,240 on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $8,168,301, resulting in an overstatement of $106,939. This error was subsequently corrected on the final SEFA. C. Coronavirus State and Local Fiscal Recovery Funds ? The State reported subrecipient expenditures in the amount of $7,435,217 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over subrecipient monitoring, we noted that for 5 of 10 subrecipients selected for testwork that the sample selection had been incorrectly identified as a subrecipient, resulting in an overstatement of $5,326,620. We further noted as part of our testwork over procurement, that 18 of 48 contracts selected for testwork had incorrectly been identified as a contract and instead of a subrecipient grant agreement. There were no expenditures associated with these agreements, and as a result, there was no impact on the amount reported on the SEFA within the amounts provided to subrecipients column. The error was subsequently corrected on the final SEFA to properly present $2,108,597 as passed through to subrecipient. D. Epidemiology and Laboratory Capacity for Infectious Diseases - The State reported subrecipient expenditures in the amount of $4,879,473 on the draft SEFA within the amounts provided to subrecipients column. During our testwork related to FFATA reporting, we noted that 1 of 4 items selected for testwork did not represent a tier-one award but instead was a contract. The impact on the amount reported on the SEFA within the amounts provided to subrecipients column was an overstatement of $8,400. The error was subsequently corrected on the final SEFA to properly present $4,871,073 as passed through to subrecipient. E. Temporary Assistance for Needy Families - The State did not report any subrecipient expenditures on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $3,307,974, resulting in an understatement of $3,307,974. This error was subsequently corrected on the final SEFA. Cause The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient to ensure the proper identification of subrecipients. Effect The effect of the condition found is that subrecipient expenditures were not accurately presented on the SEFA. Questioned Costs None. Recommendation We recommend that the State review its existing statewide internal controls over vendor versus subrecipient determination to ensure they are operating effectively to properly identify a vendor versus a subrecipient. This will ensure that the amounts presented as pass through as subrecipient expenditures on the SEFA are complete and accurate. Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services
Finding Reference Number: 2022-002 NH Department of Administrative Services Federal Transit Cluster and COVID-19 Federal Transit Cluster (Assistance Listing #20.507and #20.526) Airport Improvement Program and COVID-19 Airport Improvement Program (Assistance Listing #20.106) COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers 2020G996115, 2021G996115, SLFRP0145, NUK50CK000522, 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2019, 2020, 2021 U.S. Department of Transportation, U.S. Department of Treasury, U.S. Department of Health and Human Services Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition The State of New Hampshire (the State) entered into contracts and subrecipient grant agreements to assist with the administration of its federal awards. As part of the Schedule of Expenditures of Federal Awards (SEFA) preparation process, the Department of Administrative Services requested information from each Department related to federal expenditures made by federal program and the portion of those expenditures that were passed through to subrecipients. For the year ended June 30, 2022, the State reported approximately $3.5 billion in federal expenditures on the SEFA. Of the total expenditures reported, approximately $783 million was reported as amounts passed through to subrecipients. During our audit, we identified several instances where the State inaccurately reported the value of the amounts passed through to subrecipients for certain federal programs. Specifically, we noted the following: A. Federal Transit Cluster - The State reported subrecipient expenditures in the amount of $4,038,163 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over procurement, we noted that 1 of 4 contracts selected for testwork was incorrectly identified as a contract. Upon further review and inquiry of management, the actual subrecipient expenditures for the year ended June 30, 2022 were $375,302, resulting in an overstatement of $3,662,861. This error was subsequently corrected on the final SEFA. B. Airport Improvement Program - The State reported subrecipient expenditures in the amount of $8,275,240 on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $8,168,301, resulting in an overstatement of $106,939. This error was subsequently corrected on the final SEFA. C. Coronavirus State and Local Fiscal Recovery Funds ? The State reported subrecipient expenditures in the amount of $7,435,217 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over subrecipient monitoring, we noted that for 5 of 10 subrecipients selected for testwork that the sample selection had been incorrectly identified as a subrecipient, resulting in an overstatement of $5,326,620. We further noted as part of our testwork over procurement, that 18 of 48 contracts selected for testwork had incorrectly been identified as a contract and instead of a subrecipient grant agreement. There were no expenditures associated with these agreements, and as a result, there was no impact on the amount reported on the SEFA within the amounts provided to subrecipients column. The error was subsequently corrected on the final SEFA to properly present $2,108,597 as passed through to subrecipient. D. Epidemiology and Laboratory Capacity for Infectious Diseases - The State reported subrecipient expenditures in the amount of $4,879,473 on the draft SEFA within the amounts provided to subrecipients column. During our testwork related to FFATA reporting, we noted that 1 of 4 items selected for testwork did not represent a tier-one award but instead was a contract. The impact on the amount reported on the SEFA within the amounts provided to subrecipients column was an overstatement of $8,400. The error was subsequently corrected on the final SEFA to properly present $4,871,073 as passed through to subrecipient. E. Temporary Assistance for Needy Families - The State did not report any subrecipient expenditures on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $3,307,974, resulting in an understatement of $3,307,974. This error was subsequently corrected on the final SEFA. Cause The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient to ensure the proper identification of subrecipients. Effect The effect of the condition found is that subrecipient expenditures were not accurately presented on the SEFA. Questioned Costs None. Recommendation We recommend that the State review its existing statewide internal controls over vendor versus subrecipient determination to ensure they are operating effectively to properly identify a vendor versus a subrecipient. This will ensure that the amounts presented as pass through as subrecipient expenditures on the SEFA are complete and accurate. Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services
Finding Reference Number: 2022-021 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: NA Statistically Valid Sample: No Criteria5 A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient?s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition As part of the Temporary Assistance for Needy Families program (TANF), the New Hampshire Department of Health and Human Services (the Department) enters into grant agreements with local entities to provide services to support eligible participants. During the year ended June 30, 2022, the Department passed through $3,307,974 to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. For 1 of 7 subrecipients selected for testwork, per review of the grant agreement, we noted that the agreement did not contain any funding to be paid under the TANF program and should not have been identified as a TANF subrecipient. The total amount paid to the entity was $13,530. B. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for 4 of the remaining 6 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. The subrecipient?s unique identifier was not communicated for 1 of the remaining 6 subrecipients selected for testwork b. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 2 of the remaining 6 subrecipients selected for testwork c. Identification of whether the award is R&D was not communicated for 4 of the remaining 6 subrecipients selected for testwork. C. The Department did not perform a risk assessment for all subrecipients selected for testwork. As a result, it is unclear if any additional targeted subrecipient monitoring should have been performed. D. For 1 of the remaining 6 subrecipients selected for testwork, there was no evidence that a programmatic monitoring review was completed for the subrecipient as required by their subrecipient monitoring policy. As there was no risk assessment performed for the subrecipient, it was unclear as to whether a programmatic monitoring visit should have been performed. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that federal reimbursement of expenditures are only disbursed to entities that have an approved subrecipient grant agreement. In addition, there are insufficient internal controls and procedures to ensure that award identification information is properly communicated with grant agreements and that risk assessments are performed to ensure sufficient during the awarded monitoring is performed over all subrecipients. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b), CFR section 200.521 and 2 CFR sections 200.332(d) through (f). Questioned Costs $13,530 ? the amount in bullet A above. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.251. This would include ensuring that: 1. The Department has an approved subrecipient grant agreement prior to making any disbursements to an entity; 2. All required award information is communicated to subrecipients; 3. A documented risk assessment is performed over all subrecipients, and the results of that risk assessment is used to evaluate the types of monitoring procedures that will be performed over the subrecipient; and 4. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. View of Responsible Officials A. We concur with this finding. The Department utilized an internally available copy of the Management Log, which lists vendor?s determinations. This is a copy of the log, not the original, official copy. There is a delay in updating this copy from the original, and incorrect information had been initially entered. The Department is moving this log to software which allows all Department employees to view the same log, while limiting the number of individuals who have access to make changes. Implementation has been completed as of March 2023. B. We concur with this finding. However, we believe this was an isolated incident as the TANF CFDA number (93.558) used was very similar to correct CFDA number (93.778) that should have been documented. C. 200.332 requirements a. We do not concur with this finding. The contract for Mt Prospect became effective 8/4/21, prior to the 4/22 inception of the UEI. The DUNS number, as in effect at that time, is noticed in Exhibit J of the contract. b. We concur with three of the four findings. Two of the four contracts pre-date the template update requiring the notice an indirect cost rate. Indirect cost rate for federal awards (including if the de minimis rate is charged per 2 CFR section 200.414) were added to Exhibit C of the Department?s contracts in April 2020. One of the contracts did not indicate an indirect cost rate as required. One of the contracts notes the indirect cost rate in the Notes of their financial details. c. One of the two contracts pre-dates the template update requiring the notice the identification of R&D. R&D identifications for federal awards were added to Exhibit C of the Department?s contracts in April 2020 One of the two contracts did not identify whether the contract was R&D as required. D. Subrecipient Risk Assessment ? We concur with the finding. We consider the finding to be fully resolved through Department policy Department policy and Department wide implementation. However, it should be noted full compliance will not be achieved for one to two contact cycles due to timing. The Department began addressing the issue of Subrecipient Monitoring issue in June 2017 when the first Grants Administrator was hired. The Department finalized the Subrecipient Monitoring Policy, which encompasses the financial and programmatic risk assessments as well as the subrecipient monitoring, on June 1, 2018. The Department provided user training on the subject in February and September 2018, training over one hundred forty-six staff. However, only brand new procurements utilized this policy during the initial roll out of this policy. The Department hired a new Grants Administrator in May 2019. The full Subrecipient Monitoring policy rolled out to all procurements, including sole source, amendments, and renewals, effective August 1, 2020. The Contracts Unit received specialized subrecipient monitoring training on May 13 and October 28, 2020. Department wide training to all staff occurred weekly between September 8 and November 3, 2020. The Grants Office provided additional targeted training to Program staff through team meetings. Over one hundred fifty Program and Finance staff received training. Annual training will be held in September each year. Refresher training or training for new staff is available upon request from the Grants Office. The Grants Office website offers Program, Finance, and Contracts Bureau staff access to the subrecipient monitoring policy, as well as training modules, slides, and tools. The training has also been recorded and is available on this site. The Subrecipient Monitoring Policy requires Program to determine whether any vendor which receives funds in exchange for goods or services is a Contractor or Subrecipient. Determined subrecipients receive a Management Questionnaire, which includes a ten question questionnaire and requirements for submitting financial data. This information is used to populate the Risk Assessment Tool, which shows any risks pertinent to a subrecipient and the subaward. Based on the risks shown, Program chooses monitoring activities to mitigate the risks and the Contracts Bureau memorializes these choices in the contract. The Grants Office continues to work closely with the Contracts Bureau to ensure compliance with the Subrecipient Monitoring policy. C. and D. It is also important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates, which did not include the required notifications under 200.332, were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. E. We concur there was no formal documentation of any monitoring activity. Due to staff turnover a new administrator has been hired and unable to furnish the monitoring that took place during FY22. However, a program site review during FY23 was performed and financial monitoring of invoices has also taken place. Anticipated Completion Date: July, 2023 Contact Person: Melissa Kelleher, Administrator Rejoinder As documented above in Bullet B of the condition found, the Department did not properly communicate all required award information to the subrecipient. Once aware of the noncompliance, the Department should have timely communicated this information to its subrecipients.
Finding Reference Number: 2022-023 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Federal Reporting Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition During the year ended June 30, 2022, we noted the New Hampshire Department of Health and Human Services (the Department) passed through $3,307,974 in Temporary Assistance to Needy Families funds to subrecipients. During out testwork over FFATA reporting at the Department, we selected 6 FFATA reports for testing and noted the following: See Schedule of Findings and Questioned Costs for Chart/Table Cause The cause of the condition found is due to a lack of policies and procedures, including internal controls, to ensure timely and accurate FFATA reporting. The Department uses a matrix to assist in the submission of FFATA reports, however, this schedule is not maintained and is overridden each time a new report is filed, resulting in our inability to validate the amount of the award amount reported for reach report tested within our sample. Effect The effect of the condition found is that the Department did not have sufficient internal controls in accordance with 2 CFR section 200.303. Questioned Costs None. Recommendation We recommend that the Department implement internal controls, policies, and procedures, across all Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements. View of Responsible Officials The Department partially concurs as follows: The Department?s position is that it maintains compliance with the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Department agrees that during the year ended June 30, 2022, not all of the tested FFATA reports were deemed complete and accurate due to internal control considerations. The Department will review current practices regarding the internal control of financial information included in the G&C PDF?s which are the basis of the FFATA reporting with the objective of accurately reporting the specific amounts of Federal Funding content by FAIN so as to facilitate the accurate and timely reporting of FFATA in accordance with the Act. Anticipated Completion Date: September 30, 2023 Contact Person: PJ Nadeau, Administrator
Finding Reference Number: 2022-024 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Special Tests and Provisions: Penalty for Failure to Comply with Work Verification Plan Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2021-025 Statistically Valid Sample: No The State agency must maintain adequate documentation, verification, and internal control procedures to ensure the accuracy of the data used in calculating work participation rates. In so doing, it must have in place procedures to (a) determine whether its work activities may count for participation rate purposes; (b) determine how to count and verify reported hours of work; (c) identify who is a work eligible individual; and (d) control internal data transmission and accuracy. Each State agency must comply with its HHS-approved Work Verification Plan in effect for the period that is audited. HHS may penalize the State by an amount not less than one percent and not more than five percent of the SFAG for violation of this provision (42 USC 601, 602, 607, and 609); 45 CFR sections 261.60, 261.61, 261.62, 261.63, 261.64, and 261.65). Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition During our testwork related to compliance with the New Hampshire Department of Health and Human Services (the Department) work verification plan we noted the following: A. For 5 of 60 participants selected for testwork, the participant did not have a signed active employment plan for the period selected for testwork. As there was no active employment plan, we were unable to verify if the participant was in compliance with their required work requirements for the period tested. B. For 7 of 60 participants selected for testwork, there was insufficient documentation to support the number of hours worked within the New Heights system for the participant. Cause The cause of the condition found was a result of inadequate review internal controls in place to ensure that participants have an active signed employment plan in place, that sufficient documentation is maintained to support the number of work hours reported by participants, and that the hours worked is accurately reported within the New Heights system. Effect The effect of the condition found is that the State may not be in compliance with its work verification plan and would not be able to identify the noncompliance. Questioned Costs Not determinable. Recommendation We recommend that the Department enhance its existing internal controls and procedures to ensure that participant employment plans are obtained, documentation used to support participant work hours is maintained, that the hours reported agree to the documented hours worked and that the work hours are accurately reflected within the New Heights system. View of Responsible Officials We concur with the finding. Corrective Action: Condition A The Bureau of Employment Supports has been undergoing massive programmatic changes over the past 2 to 3 years. As part of those changes, there has been an updated Work Verification Plan submitted which will help to address some areas where errors have occurred. Keeping in mind that for a period of close to 2 years, due to the COVID pandemic, NHEP was not holding participants accountable for not returning signed employment plans to NHEP staff. The focus for that time was to ensure that families were housed, fed and safe, therefore, services focused on their immediate needs. Participants who entered the NHEP program during that time were not held accountable to returning a signed employment plan therefore it did not become part of their routine with NHEP. While COVID restrictions have been lifted, participants seem to have needed some time to reintegrate into the NHEP program and the mandatory expectations. NHEP staff and leadership will continue to remind participants and become more diligent in ensuring that signed employment plans are on the forefront of their daily responsibilities. It should be noted that in a couple of instances, employment plans were created as part of a Service Determination Appointment and very quickly after the participant was deemed exempt from the Work Program (NHEP) so the employment plan was not necessary and became a moot point. A Director?s Memo will be sent out by the end of this week which will allow Employment Plans to be acknowledged and accepted by the participant in multiple ways (not just with a wet signature) thereby increasing the likelihood of participants returning accepted employment plans to NHEP staff. Making this shift will mitigate the difficulties that are causing participants to not return their signed employment plans to NHEP staff and will decrease instances where there is not an accepted employment plan on file. NHEP leadership will hold a state wide mandatory staff training where ways to prioritize the monitoring and obtainment of accepted employment plans will be outlined and discussed. Field Support Managers will continue to monitor their staff on a quarterly basis, however, will add a monthly check on having accepted employment plans to their responsibilities. Condition B Part of the changes that NHEP has implemented have included a new Activity Tracking form which has made tracking hours more efficient and easier for the participant as well as the Employment Counselor. We believe that this activity tracker as well as the decrease in mandatory forms will allow for more accuracy and fewer errors moving forward. Uploading documents into the e-folder was found to be error prone, therefore, on March 1, 2023, NHEP leadership provided guidance and training on a specific process of indexing and scanning documents to ensure that moving forward the Employment Counselors are checking their e-folder?s to ensure that documents are properly uploaded and visible. This process was initially sent out to the field as a suggestion in 9/2022, however, on 3/1/23 this process was sent out as an expected process moving forward. Also, through cursory investigations, we believe that this new process, combined with the new Activity Tracking form, has already shown to be effective in improving the accuracy of supporting and recording hours. NHEP leadership has also been working with the NEW HEIGHTS system to streamline the process of uploading documents to further decrease the potential for errors. A change request form was submitted approximately one year ago. Also during the time period of this audit, NHEP was requiring pay stubs from employed participants and completing ?overrides? of the number of work hours that a participant worked during the week if that number was different than what was auto-populating based on information obtained by and entered by eligibility. NHEP discontinued that practice. NHEP no longer requires pay stubs from participants as that is a function of eligibility. NHEP utilizes the number of hours worked per week based on the number of hours entered by eligibility. This change will ensure that employment hour errors no longer occur. In order to address issues of audit findings, within the next 90 days, NHEP leadership is holding a state wide mandatory staff training where more in-depth information on the audit process will be shared including audit ?tests?, ?questions? and ?corrective action plans?. Historically in NH, the audit process was not shared with the NHEP staff making them unaware of the expectations and/or findings of the audit. NHEP staff were trained to complete certain processes and enter particular data but were never able to connect that back to anything. While we have been introducing this process more and more to our staff, we intend to hold a training to help them more thoroughly understand why they are doing what they are doing and remind them that what they do is reviewed for accuracy as part of the federal audit process. We believe that this transparency will create buy-in from the staff to put systems in place for themselves and to self-monitor more. Anticipated Completion Date: December 31, 2023 Contact: Brigitte Bowmar, Program and Workforce Administrator III
Finding Reference Number: 2022-002 NH Department of Administrative Services Federal Transit Cluster and COVID-19 Federal Transit Cluster (Assistance Listing #20.507and #20.526) Airport Improvement Program and COVID-19 Airport Improvement Program (Assistance Listing #20.106) COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers 2020G996115, 2021G996115, SLFRP0145, NUK50CK000522, 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2019, 2020, 2021 U.S. Department of Transportation, U.S. Department of Treasury, U.S. Department of Health and Human Services Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition The State of New Hampshire (the State) entered into contracts and subrecipient grant agreements to assist with the administration of its federal awards. As part of the Schedule of Expenditures of Federal Awards (SEFA) preparation process, the Department of Administrative Services requested information from each Department related to federal expenditures made by federal program and the portion of those expenditures that were passed through to subrecipients. For the year ended June 30, 2022, the State reported approximately $3.5 billion in federal expenditures on the SEFA. Of the total expenditures reported, approximately $783 million was reported as amounts passed through to subrecipients. During our audit, we identified several instances where the State inaccurately reported the value of the amounts passed through to subrecipients for certain federal programs. Specifically, we noted the following: A. Federal Transit Cluster - The State reported subrecipient expenditures in the amount of $4,038,163 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over procurement, we noted that 1 of 4 contracts selected for testwork was incorrectly identified as a contract. Upon further review and inquiry of management, the actual subrecipient expenditures for the year ended June 30, 2022 were $375,302, resulting in an overstatement of $3,662,861. This error was subsequently corrected on the final SEFA. B. Airport Improvement Program - The State reported subrecipient expenditures in the amount of $8,275,240 on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $8,168,301, resulting in an overstatement of $106,939. This error was subsequently corrected on the final SEFA. C. Coronavirus State and Local Fiscal Recovery Funds ? The State reported subrecipient expenditures in the amount of $7,435,217 on the draft SEFA within the amounts provided to subrecipients column. During our testwork over subrecipient monitoring, we noted that for 5 of 10 subrecipients selected for testwork that the sample selection had been incorrectly identified as a subrecipient, resulting in an overstatement of $5,326,620. We further noted as part of our testwork over procurement, that 18 of 48 contracts selected for testwork had incorrectly been identified as a contract and instead of a subrecipient grant agreement. There were no expenditures associated with these agreements, and as a result, there was no impact on the amount reported on the SEFA within the amounts provided to subrecipients column. The error was subsequently corrected on the final SEFA to properly present $2,108,597 as passed through to subrecipient. D. Epidemiology and Laboratory Capacity for Infectious Diseases - The State reported subrecipient expenditures in the amount of $4,879,473 on the draft SEFA within the amounts provided to subrecipients column. During our testwork related to FFATA reporting, we noted that 1 of 4 items selected for testwork did not represent a tier-one award but instead was a contract. The impact on the amount reported on the SEFA within the amounts provided to subrecipients column was an overstatement of $8,400. The error was subsequently corrected on the final SEFA to properly present $4,871,073 as passed through to subrecipient. E. Temporary Assistance for Needy Families - The State did not report any subrecipient expenditures on the draft SEFA within the amounts provided to subrecipients column. Upon further review and inquiry of management, management determined the actual subrecipient expenditures for the year ended June 30, 2022 were $3,307,974, resulting in an understatement of $3,307,974. This error was subsequently corrected on the final SEFA. Cause The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient to ensure the proper identification of subrecipients. Effect The effect of the condition found is that subrecipient expenditures were not accurately presented on the SEFA. Questioned Costs None. Recommendation We recommend that the State review its existing statewide internal controls over vendor versus subrecipient determination to ensure they are operating effectively to properly identify a vendor versus a subrecipient. This will ensure that the amounts presented as pass through as subrecipient expenditures on the SEFA are complete and accurate. Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services
Finding Reference Number: 2022-021 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: NA Statistically Valid Sample: No Criteria5 A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient?s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition As part of the Temporary Assistance for Needy Families program (TANF), the New Hampshire Department of Health and Human Services (the Department) enters into grant agreements with local entities to provide services to support eligible participants. During the year ended June 30, 2022, the Department passed through $3,307,974 to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. For 1 of 7 subrecipients selected for testwork, per review of the grant agreement, we noted that the agreement did not contain any funding to be paid under the TANF program and should not have been identified as a TANF subrecipient. The total amount paid to the entity was $13,530. B. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for 4 of the remaining 6 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. The subrecipient?s unique identifier was not communicated for 1 of the remaining 6 subrecipients selected for testwork b. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 2 of the remaining 6 subrecipients selected for testwork c. Identification of whether the award is R&D was not communicated for 4 of the remaining 6 subrecipients selected for testwork. C. The Department did not perform a risk assessment for all subrecipients selected for testwork. As a result, it is unclear if any additional targeted subrecipient monitoring should have been performed. D. For 1 of the remaining 6 subrecipients selected for testwork, there was no evidence that a programmatic monitoring review was completed for the subrecipient as required by their subrecipient monitoring policy. As there was no risk assessment performed for the subrecipient, it was unclear as to whether a programmatic monitoring visit should have been performed. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that federal reimbursement of expenditures are only disbursed to entities that have an approved subrecipient grant agreement. In addition, there are insufficient internal controls and procedures to ensure that award identification information is properly communicated with grant agreements and that risk assessments are performed to ensure sufficient during the awarded monitoring is performed over all subrecipients. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b), CFR section 200.521 and 2 CFR sections 200.332(d) through (f). Questioned Costs $13,530 ? the amount in bullet A above. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.251. This would include ensuring that: 1. The Department has an approved subrecipient grant agreement prior to making any disbursements to an entity; 2. All required award information is communicated to subrecipients; 3. A documented risk assessment is performed over all subrecipients, and the results of that risk assessment is used to evaluate the types of monitoring procedures that will be performed over the subrecipient; and 4. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. View of Responsible Officials A. We concur with this finding. The Department utilized an internally available copy of the Management Log, which lists vendor?s determinations. This is a copy of the log, not the original, official copy. There is a delay in updating this copy from the original, and incorrect information had been initially entered. The Department is moving this log to software which allows all Department employees to view the same log, while limiting the number of individuals who have access to make changes. Implementation has been completed as of March 2023. B. We concur with this finding. However, we believe this was an isolated incident as the TANF CFDA number (93.558) used was very similar to correct CFDA number (93.778) that should have been documented. C. 200.332 requirements a. We do not concur with this finding. The contract for Mt Prospect became effective 8/4/21, prior to the 4/22 inception of the UEI. The DUNS number, as in effect at that time, is noticed in Exhibit J of the contract. b. We concur with three of the four findings. Two of the four contracts pre-date the template update requiring the notice an indirect cost rate. Indirect cost rate for federal awards (including if the de minimis rate is charged per 2 CFR section 200.414) were added to Exhibit C of the Department?s contracts in April 2020. One of the contracts did not indicate an indirect cost rate as required. One of the contracts notes the indirect cost rate in the Notes of their financial details. c. One of the two contracts pre-dates the template update requiring the notice the identification of R&D. R&D identifications for federal awards were added to Exhibit C of the Department?s contracts in April 2020 One of the two contracts did not identify whether the contract was R&D as required. D. Subrecipient Risk Assessment ? We concur with the finding. We consider the finding to be fully resolved through Department policy Department policy and Department wide implementation. However, it should be noted full compliance will not be achieved for one to two contact cycles due to timing. The Department began addressing the issue of Subrecipient Monitoring issue in June 2017 when the first Grants Administrator was hired. The Department finalized the Subrecipient Monitoring Policy, which encompasses the financial and programmatic risk assessments as well as the subrecipient monitoring, on June 1, 2018. The Department provided user training on the subject in February and September 2018, training over one hundred forty-six staff. However, only brand new procurements utilized this policy during the initial roll out of this policy. The Department hired a new Grants Administrator in May 2019. The full Subrecipient Monitoring policy rolled out to all procurements, including sole source, amendments, and renewals, effective August 1, 2020. The Contracts Unit received specialized subrecipient monitoring training on May 13 and October 28, 2020. Department wide training to all staff occurred weekly between September 8 and November 3, 2020. The Grants Office provided additional targeted training to Program staff through team meetings. Over one hundred fifty Program and Finance staff received training. Annual training will be held in September each year. Refresher training or training for new staff is available upon request from the Grants Office. The Grants Office website offers Program, Finance, and Contracts Bureau staff access to the subrecipient monitoring policy, as well as training modules, slides, and tools. The training has also been recorded and is available on this site. The Subrecipient Monitoring Policy requires Program to determine whether any vendor which receives funds in exchange for goods or services is a Contractor or Subrecipient. Determined subrecipients receive a Management Questionnaire, which includes a ten question questionnaire and requirements for submitting financial data. This information is used to populate the Risk Assessment Tool, which shows any risks pertinent to a subrecipient and the subaward. Based on the risks shown, Program chooses monitoring activities to mitigate the risks and the Contracts Bureau memorializes these choices in the contract. The Grants Office continues to work closely with the Contracts Bureau to ensure compliance with the Subrecipient Monitoring policy. C. and D. It is also important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates, which did not include the required notifications under 200.332, were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. E. We concur there was no formal documentation of any monitoring activity. Due to staff turnover a new administrator has been hired and unable to furnish the monitoring that took place during FY22. However, a program site review during FY23 was performed and financial monitoring of invoices has also taken place. Anticipated Completion Date: July, 2023 Contact Person: Melissa Kelleher, Administrator Rejoinder As documented above in Bullet B of the condition found, the Department did not properly communicate all required award information to the subrecipient. Once aware of the noncompliance, the Department should have timely communicated this information to its subrecipients.
Finding Reference Number: 2022-023 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Federal Reporting Type of Finding: Significant Deficiency Prior Year Finding: None Statistically Valid Sample: No Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition During the year ended June 30, 2022, we noted the New Hampshire Department of Health and Human Services (the Department) passed through $3,307,974 in Temporary Assistance to Needy Families funds to subrecipients. During out testwork over FFATA reporting at the Department, we selected 6 FFATA reports for testing and noted the following: See Schedule of Findings and Questioned Costs for Chart/Table Cause The cause of the condition found is due to a lack of policies and procedures, including internal controls, to ensure timely and accurate FFATA reporting. The Department uses a matrix to assist in the submission of FFATA reports, however, this schedule is not maintained and is overridden each time a new report is filed, resulting in our inability to validate the amount of the award amount reported for reach report tested within our sample. Effect The effect of the condition found is that the Department did not have sufficient internal controls in accordance with 2 CFR section 200.303. Questioned Costs None. Recommendation We recommend that the Department implement internal controls, policies, and procedures, across all Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements. View of Responsible Officials The Department partially concurs as follows: The Department?s position is that it maintains compliance with the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Department agrees that during the year ended June 30, 2022, not all of the tested FFATA reports were deemed complete and accurate due to internal control considerations. The Department will review current practices regarding the internal control of financial information included in the G&C PDF?s which are the basis of the FFATA reporting with the objective of accurately reporting the specific amounts of Federal Funding content by FAIN so as to facilitate the accurate and timely reporting of FFATA in accordance with the Act. Anticipated Completion Date: September 30, 2023 Contact Person: PJ Nadeau, Administrator
Finding Reference Number: 2022-024 NH Department of Health and Human Services Temporary Assistance for Needy Families and COVID-19 Temporary Assistance for Needy Families (Assistance Listing #93.558) Federal Award Numbers: 2021G996115, 2021G990228, 2022G996115 Federal Award Year: 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Special Tests and Provisions: Penalty for Failure to Comply with Work Verification Plan Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2021-025 Statistically Valid Sample: No The State agency must maintain adequate documentation, verification, and internal control procedures to ensure the accuracy of the data used in calculating work participation rates. In so doing, it must have in place procedures to (a) determine whether its work activities may count for participation rate purposes; (b) determine how to count and verify reported hours of work; (c) identify who is a work eligible individual; and (d) control internal data transmission and accuracy. Each State agency must comply with its HHS-approved Work Verification Plan in effect for the period that is audited. HHS may penalize the State by an amount not less than one percent and not more than five percent of the SFAG for violation of this provision (42 USC 601, 602, 607, and 609); 45 CFR sections 261.60, 261.61, 261.62, 261.63, 261.64, and 261.65). Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition During our testwork related to compliance with the New Hampshire Department of Health and Human Services (the Department) work verification plan we noted the following: A. For 5 of 60 participants selected for testwork, the participant did not have a signed active employment plan for the period selected for testwork. As there was no active employment plan, we were unable to verify if the participant was in compliance with their required work requirements for the period tested. B. For 7 of 60 participants selected for testwork, there was insufficient documentation to support the number of hours worked within the New Heights system for the participant. Cause The cause of the condition found was a result of inadequate review internal controls in place to ensure that participants have an active signed employment plan in place, that sufficient documentation is maintained to support the number of work hours reported by participants, and that the hours worked is accurately reported within the New Heights system. Effect The effect of the condition found is that the State may not be in compliance with its work verification plan and would not be able to identify the noncompliance. Questioned Costs Not determinable. Recommendation We recommend that the Department enhance its existing internal controls and procedures to ensure that participant employment plans are obtained, documentation used to support participant work hours is maintained, that the hours reported agree to the documented hours worked and that the work hours are accurately reflected within the New Heights system. View of Responsible Officials We concur with the finding. Corrective Action: Condition A The Bureau of Employment Supports has been undergoing massive programmatic changes over the past 2 to 3 years. As part of those changes, there has been an updated Work Verification Plan submitted which will help to address some areas where errors have occurred. Keeping in mind that for a period of close to 2 years, due to the COVID pandemic, NHEP was not holding participants accountable for not returning signed employment plans to NHEP staff. The focus for that time was to ensure that families were housed, fed and safe, therefore, services focused on their immediate needs. Participants who entered the NHEP program during that time were not held accountable to returning a signed employment plan therefore it did not become part of their routine with NHEP. While COVID restrictions have been lifted, participants seem to have needed some time to reintegrate into the NHEP program and the mandatory expectations. NHEP staff and leadership will continue to remind participants and become more diligent in ensuring that signed employment plans are on the forefront of their daily responsibilities. It should be noted that in a couple of instances, employment plans were created as part of a Service Determination Appointment and very quickly after the participant was deemed exempt from the Work Program (NHEP) so the employment plan was not necessary and became a moot point. A Director?s Memo will be sent out by the end of this week which will allow Employment Plans to be acknowledged and accepted by the participant in multiple ways (not just with a wet signature) thereby increasing the likelihood of participants returning accepted employment plans to NHEP staff. Making this shift will mitigate the difficulties that are causing participants to not return their signed employment plans to NHEP staff and will decrease instances where there is not an accepted employment plan on file. NHEP leadership will hold a state wide mandatory staff training where ways to prioritize the monitoring and obtainment of accepted employment plans will be outlined and discussed. Field Support Managers will continue to monitor their staff on a quarterly basis, however, will add a monthly check on having accepted employment plans to their responsibilities. Condition B Part of the changes that NHEP has implemented have included a new Activity Tracking form which has made tracking hours more efficient and easier for the participant as well as the Employment Counselor. We believe that this activity tracker as well as the decrease in mandatory forms will allow for more accuracy and fewer errors moving forward. Uploading documents into the e-folder was found to be error prone, therefore, on March 1, 2023, NHEP leadership provided guidance and training on a specific process of indexing and scanning documents to ensure that moving forward the Employment Counselors are checking their e-folder?s to ensure that documents are properly uploaded and visible. This process was initially sent out to the field as a suggestion in 9/2022, however, on 3/1/23 this process was sent out as an expected process moving forward. Also, through cursory investigations, we believe that this new process, combined with the new Activity Tracking form, has already shown to be effective in improving the accuracy of supporting and recording hours. NHEP leadership has also been working with the NEW HEIGHTS system to streamline the process of uploading documents to further decrease the potential for errors. A change request form was submitted approximately one year ago. Also during the time period of this audit, NHEP was requiring pay stubs from employed participants and completing ?overrides? of the number of work hours that a participant worked during the week if that number was different than what was auto-populating based on information obtained by and entered by eligibility. NHEP discontinued that practice. NHEP no longer requires pay stubs from participants as that is a function of eligibility. NHEP utilizes the number of hours worked per week based on the number of hours entered by eligibility. This change will ensure that employment hour errors no longer occur. In order to address issues of audit findings, within the next 90 days, NHEP leadership is holding a state wide mandatory staff training where more in-depth information on the audit process will be shared including audit ?tests?, ?questions? and ?corrective action plans?. Historically in NH, the audit process was not shared with the NHEP staff making them unaware of the expectations and/or findings of the audit. NHEP staff were trained to complete certain processes and enter particular data but were never able to connect that back to anything. While we have been introducing this process more and more to our staff, we intend to hold a training to help them more thoroughly understand why they are doing what they are doing and remind them that what they do is reviewed for accuracy as part of the federal audit process. We believe that this transparency will create buy-in from the staff to put systems in place for themselves and to self-monitor more. Anticipated Completion Date: December 31, 2023 Contact: Brigitte Bowmar, Program and Workforce Administrator III
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $59,000 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $15,607,079 were expended and reported on the Newton County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to the private staffing companies utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon prices. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the private staffing companies and in the service of the School District for a stated period of time was not reflected within the associated contracts. Therefore, expenditures totaling $59,000 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $59,000 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We do not concur with this finding. The School District relied upon guidance provided by the Georgia Department of Education related to the ESSER program to ensure appropriate use of funds. The expenditure was clearly delineated within the ESSER budget. The expenditure was initially approved by the Georgia Department of Education on June 6, 2021. Subsequent budget amendments were also submitted and approved by the Georgia Department of Education, indicating to the School District that the expenditure was for an allowable use of funds. Auditor?s Concluding Remarks: The School District states that it relied upon guidance provided by the Georgia Department of Education related to the ESSER program to ensure appropriate use of funds. However, the School District is responsible for ensuring that it complies with requirements of its federal programs, including ensuring that it establishes and maintains effective internal control over federal awards pursuant to the Uniform Guidance and ensuring that the board-approved procurement policy is followed. Additionally, auditors contacted ED?s ESSER program management to discuss the allowability of these bonus payments as ED is the grantor of the funds and the cognizant agency charged with administering the ESSER program. Officials at ED advised auditors that bonuses may be allowable if such bonuses are reflected within the contract; however, as noted previously, no such contract provisions were present and amounts were paid in excess of the rates reflected within the associated contracts. Moreover, ED emphasized that published guidance associated with the issuance of bonuses or premium pay from ESSER funds pertained to school personnel, not contractors. The Georgia Department of Audits and Accounts (DOAA) acknowledges the overwhelming burden placed on the School District due to the effects of the COVID-19 pandemic and the additional care needed to ensure student and staff safety. However, given the information reflected above, we reaffirm our finding and will review the status of the finding during our next audit.
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $59,000 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $15,607,079 were expended and reported on the Newton County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to the private staffing companies utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon prices. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the private staffing companies and in the service of the School District for a stated period of time was not reflected within the associated contracts. Therefore, expenditures totaling $59,000 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $59,000 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We do not concur with this finding. The School District relied upon guidance provided by the Georgia Department of Education related to the ESSER program to ensure appropriate use of funds. The expenditure was clearly delineated within the ESSER budget. The expenditure was initially approved by the Georgia Department of Education on June 6, 2021. Subsequent budget amendments were also submitted and approved by the Georgia Department of Education, indicating to the School District that the expenditure was for an allowable use of funds. Auditor?s Concluding Remarks: The School District states that it relied upon guidance provided by the Georgia Department of Education related to the ESSER program to ensure appropriate use of funds. However, the School District is responsible for ensuring that it complies with requirements of its federal programs, including ensuring that it establishes and maintains effective internal control over federal awards pursuant to the Uniform Guidance and ensuring that the board-approved procurement policy is followed. Additionally, auditors contacted ED?s ESSER program management to discuss the allowability of these bonus payments as ED is the grantor of the funds and the cognizant agency charged with administering the ESSER program. Officials at ED advised auditors that bonuses may be allowable if such bonuses are reflected within the contract; however, as noted previously, no such contract provisions were present and amounts were paid in excess of the rates reflected within the associated contracts. Moreover, ED emphasized that published guidance associated with the issuance of bonuses or premium pay from ESSER funds pertained to school personnel, not contractors. The Georgia Department of Audits and Accounts (DOAA) acknowledges the overwhelming burden placed on the School District due to the effects of the COVID-19 pandemic and the additional care needed to ensure student and staff safety. However, given the information reflected above, we reaffirm our finding and will review the status of the finding during our next audit.
Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARP and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University is not in compliance with quarterly and annual reporting requirements for HEERF Institutional and Student Grants. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the one required annual report. During our testing of this sample for the HEERF reporting requirements at Southern Oregon University, we noted: 1) Non-Compliant Student Quarterly Reporting a. Neither of the two quarterly student reports tested had an acknowledgement that the University signed and returned to the Department of Education the Certification and Agreement and the assurance that the University has used the applicable amount of funds designated under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) to provide Emergency Financial Aid Grants to Students. Both of these were required elements of the student quarterly reporting. b. On both reports tested, the University reported total amount of emergency financial aid grants distributed, the estimated total number of students at the institution that are eligible to receive emergency financial aid grants, and the total number of students who have received an emergency financial aid grant cumulatively, not on a quarterly basis. Additionally, the reports were cumulative as of days mid-month. 2) Non-Compliant Institutional Quarterly Reporting. a. The Original report published for the third quarter of 2021 was not retained on the website. The revised report was published in January 2022. Ultimately the reports were not posted timely within the 10-day requirement. b. The first quarter of 2022 report was also published 1 day after the deadline on 4/11/2022. 3) Non-Compliant Annual Reporting a. Institutional amounts spent in accordance with section 2003(5) of the American Rescue Plan Act of 2021 were not correctly reported on the 2021 annual report. Specifically, no amounts were reported for earmarking requirements in accordance with the ARP Institutional Appropriation expended in 2021. Cause: Staff turnover and misunderstanding of reporting guidance caused the reporting non-compliance. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: Yes 2021-003 Recommendation: We recommend that the University continue to review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARP and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University is not in compliance with quarterly and annual reporting requirements for HEERF Institutional and Student Grants. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the one required annual report. During our testing of this sample for the HEERF reporting requirements at Southern Oregon University, we noted: 1) Non-Compliant Student Quarterly Reporting a. Neither of the two quarterly student reports tested had an acknowledgement that the University signed and returned to the Department of Education the Certification and Agreement and the assurance that the University has used the applicable amount of funds designated under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) to provide Emergency Financial Aid Grants to Students. Both of these were required elements of the student quarterly reporting. b. On both reports tested, the University reported total amount of emergency financial aid grants distributed, the estimated total number of students at the institution that are eligible to receive emergency financial aid grants, and the total number of students who have received an emergency financial aid grant cumulatively, not on a quarterly basis. Additionally, the reports were cumulative as of days mid-month. 2) Non-Compliant Institutional Quarterly Reporting. a. The Original report published for the third quarter of 2021 was not retained on the website. The revised report was published in January 2022. Ultimately the reports were not posted timely within the 10-day requirement. b. The first quarter of 2022 report was also published 1 day after the deadline on 4/11/2022. 3) Non-Compliant Annual Reporting a. Institutional amounts spent in accordance with section 2003(5) of the American Rescue Plan Act of 2021 were not correctly reported on the 2021 annual report. Specifically, no amounts were reported for earmarking requirements in accordance with the ARP Institutional Appropriation expended in 2021. Cause: Staff turnover and misunderstanding of reporting guidance caused the reporting non-compliance. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: Yes 2021-003 Recommendation: We recommend that the University continue to review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.
US Department of Health and Human Services Passed through the NC Dept. of Health and Human Services Program Name: Medicaid Assistance Program (Medicaid) AL #: 93.778 Finding 2022-01: Significant Deficiency in Internal Control Criteria: Uniform Guidance 2 CFR ? 200.303 requires the non-Federal entity to ?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.? Each County in the State is required to submit quarterly reports with the second party review results with a minimum number of second party reviews completed. Condition: The County is required to complete a minimum number of second party reviews and report the results to the State, which is considered a key control over eligibility determination for Medicaid cases. There is incomplete documentation of the minimum 160 cases that County indicated it performed. GK selected a sample of 10 (10%) of the second party reviews from the list of 99 completed reviews provided by the County and determined that there were no errors in the available cases. Questioned Costs: No questioned costs. Context: The County is required to complete at least 16 Adult Medicaid cases and 24 Family/Children Medicaid cases each quarter and send a summarized report to the State, for a total of 160 cases each year. The County was able to provide a list of 99 of these reviews for the audit, which is 62% of the total 160 required. Cause: Due to lack of documentation, we were not able to sample from a complete population of second party reviews. Effect: Although the 10 selected second party reviews appeared to be appropriately performed, we are unable to conclude on the effectiveness of this internal control or compliance with the State quality control requirement to ensure their review findings were appropriate and that corrections were made timely. Identification of repeat finding: This is not a repeat finding. Recommendation: We would recommend the County make a list of each second party review completed, including the case number, program, date of review, whether there were errors to be corrected. Alternatively, we would recommend that the County use the Second Party Review form provided by the State for all cases and retain a copy of the review until the completion of the audit. Views of responsible officials and planned corrective actions: The County agrees with this finding.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must 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 the 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 Found During our audit we found two (2) of forty (40) students selected for testing whose changes in enrollment status were not accurately and timely transmitted to NSLDS. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Union College (the College) generally certifies its enrollment reports through rosters provided to the NSC. However, the College is still responsible for the timely reporting of all required enrollment changes to the NSLDS. Additionally, the reporting to NSLDS for each of these students was transmitted with the status of withdrawn, when the enrollment status was graduated. Cause For one student, there was concern about passing classes and the student applied for withdrawal right at the end of the semester. However, shortly thereafter, grades were finalized and it was determined the student had earned enough credits to graduate. Due to the two concurrent submissions of withdrawn and graduated, only the withdrawal was processed and the College did not identify the error on a timely basis. For the other student with an exception identified in our sample, there was a mid-stream change in Classification of Instructional Programs (CIP) code. The spring class of Economics students had a mid-stream change in CIP code resulting in issues with the NSC submission for impacted students since they were noted as withdrawn from their old CIP code and graduated with the updated code. Only the withdrawal was processed. In addition to the student selected in our sample, this impacted 33 additional students with federal loans in the spring Economics class.Further, we noted management?s internal controls are not designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 30 or 60 day time frame. The College should implement a review of the submitted enrollment changes to the NSLDS to ensure current student enrollment changes are accurately reflected, including specific review of status changes related to situations similar to those described above where the risk of error is higher. Any differences, including when any enrollment status changes are rejected by NSC or errors in status are processed, should be identified and investigated in a timely manner. Views of Responsible Officials Recommendation accepted. Refer to the corrective action plan for further details.
FINDING 2022-002 ? NON-COMPLIANCE AND LIMITED CONTROLS OVER SUSPENSION AND DEBARMENT Criteria ? In accordance with 2 CFR 200.213 and 2 CFR part 180 non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred, or otherwise excluded. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. The requirement is for non-federal entities to check for suspended and debarred entities and persons, or obtain certifications before entering covered transactions. In addition, 2 CFR 200.303 requires that ?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.? Condition ? The Center has adopted a federal suspension and debarment policy that requires contractors with awards that exceed the Center?s small purchase threshold to provide certifications regarding their exclusion status and that of their principal officers. During our testing we were not provided copies of obtained certifications, or proof that the Center has checked on SAM.gov whether the covered contractors have been suspended, or debarred prior to entering into the covered transactions. Questioned Costs ? None, as management subsequently searched on SAM.gov and demonstrated that none of the tested contractors in covered transactions had been suspended or debarred. Effect ? The Center did not perform proper suspension and debarment procedures regarding certain vendors of covered transaction prior to obtaining their services. This could have resulted in disallowed costs by the federal grantor. Cause ? The Center has not implemented their written policy, procedures or controls to ensure compliance with the federal suspension and debarment requirements. Recommendation ? We recommend that the Center consider changing its policy to allow for checking for suspended or debarred persons or entities on SAM.gov, in addition to allowing a contractor certification as a substitute, and implement its policy by establishing procedures and internal controls to ensure that the Uniform Guidance suspension and debarment requirements are met prior to entering into each covered transaction. Views of Responsible Officials ? We agree with the auditors? finding and the accompanying recommendation that the Center implements its policy with procedures and internal controls to ensure that the Uniform Guidance suspension and debarment requirements are met.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-007. Finding: Exit Counseling Not Completed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342 Program Expenditures: $83,176,764 Program Name: Student Financial Assistance Cluster Award Number(s): P033A191286, PO33A151286, P033A141286, P063P170116, P063P180116, P007A151286, P379T180116, P379T190116, N/A Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not complete exit counseling for all necessary students within the required time period. During our testing of students who received title IV aid at the University, we noted 2 out of 25 (8%) students who received Direct Loans, did not complete exit counseling timely after leaving the Edwardsville campus. The sample was not a statistically valid sample. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with exit counseling requirements. The Edwardsville campus requires students to complete exit counseling when they leave the University after previously attending. During the year, two students attended the University, received direct loans, and withdrew during the semesters they attended, but had not completed exit counseling within 30 days of the withdraw date from the University. The exit interviews were never conducted. According to 34 CFR 685.304(b), a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR 682.604(a)(1), if a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 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 student exit counseling is completed appropriately. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. According to University officials, the students were improperly coded with an enrollment status of ?Eligible to Register?. Banner initiates exit counseling for students with enrollment codes that have a withdrawal indicator and Eligible to Register does not have that indicator. Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plan options. Exit counseling also discusses borrower rights and responsibilities. Updated student contact information will also be collected at the end of the exit counseling session. Failure to complete exit counseling may increase the likelihood of default on student loans and lack of student understanding of loan repayment options, rights and responsibilities. (Finding Code No. 2022-007, 2021-003, 2020-004, 2019-002, 2018-005, 2017- 004) RECOMMENDATION We recommend the University implement controls to identify all required exit counseling within the student financial aid department in addition to improving controls to identify exit counseling requirements within the information technology department. These controls should be monitored to ensure that all necessary students complete exit counseling within the required time frame. UNIVERSITY RESPONSE We agree and have implemented corrective actions. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, to notify students of exit counseling requirements as soon as possible. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results.
2022-002. Finding: Inadequate Procedures for Ensuring Compliance with Earmarking Requirements for the Student Support Services Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.042 Program Expenditures: $1,011,855 Program Name: TRIO ? Student Support Services Award Number(s): P042A201635 Questioned Costs: None The Southern Illinois University (University) Carbondale campus did not have adequate procedures in place to ensure the earmarking requirements for the Student Support Services program were met during the fiscal year. During our testing of earmarking requirements for TRIO Student Support Services at the University, we noted the program at the Carbondale campus served 160 students, of which 95 (59%) students met the criteria for being either low-income individuals who are first-generation college students or individuals with disabilities. The University has not implemented sufficient processes and controls over the past several years to ensure compliance with TRIO earmarking requirements. The Student Support Services Program requires that, in addition to the eligibility criteria for individual students, not less than two-thirds of the program participants will be either low-income individuals who are first-generation college students or individuals with disabilities (34 CFR Section 646.11(a)(1)). Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal laws, statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that all earmarking requirements are reviewed and monitored to ensure compliance. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials stated the failure to meet the two-thirds requirement was due to a decreasing pool of students who qualify as first-generation and low income. In addition, officials stated the student recruiting plan was insufficient to ensure that the earmarking requirement was met. Management indicated in the current year, both of these conditions were still present and contributed to the University not meeting the earmarking requirement. Without effective controls to review the participants and ensure compliance for TRIO Student Support Services, the University is at a greater risk of not meeting the minimum earmarking requirements, as well as increased likelihood of program reviews from oversight agencies. In addition, the University is at risk of being required to return funds to the Department of Education and/or becoming ineligible to administer the program. (Finding Code No. 2022-002, 2021-002, 2020-003, 2019-001, 2018-002) RECOMMENDATION We recommend the University establish processes and procedures, including plans for increasing participation in the program by targeted populations, to ensure it will meet the earmarking program requirements. We also recommend the University implement controls to identify likely disparities in expected and actual results throughout the year and take proactive corrective action as necessary. UNIVERSITY RESPONSE We agree and have implemented corrective actions. Ongoing changes at the university continue to impact the potential for enrollment growth of minority students, which directly impacts the success of the program. Realignment of support services has structured Trio programs in an area with other similar programs that serve students that meet the criteria of the program. This realignment of services is already producing positive results, and the Trio program currently meets earmarking requirements. The requirements will be documented in the upcoming Annual Performance Report once submitted to the US Department of Education for AY 2022-2023 (May 2023). We hope to sustain this progress as enrollment at the university continues to trend upward.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.
2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns Federal Agency: Various Assistance Listing Number: Various Program Expenditures: $16,320,119 Program Name: Research and Development Cluster Award Number(s): Various Questioned Costs: None Southern Illinois University (University) Carbondale campus did not have procedures in place to consistently review cash drawdowns for the Research and Development Cluster. During our testing of the University?s Research and Development Cluster cash drawdowns, we noted 18 out of 40 (45%) drawdowns totaling $1,090,049 had no evidence the drawdown had been reviewed. The sample was not a statistically valid sample. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include review of drawdowns and appropriate supporting documentation should be retained. The Fiscal Control and Internal Auditing Act (30 ILCS 10/3001) requires the establishment and maintenance of a system, or systems, of internal fiscal and administrative controls to safeguard funds against waste, loss, unauthorized use, and misappropriation. University officials indicated there was no formal process in place in place to review and approve drawdowns due to believing the informal process was adequate. The failure to review drawdown requests increases the likelihood of noncompliance with laws and regulations. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University establish processes and procedures to ensure all cash drawdowns are reviewed, approved, and documentation of the review and approval is maintained. UNIVERSITY RESPONSE We agree and have implemented corrective actions. We did not have a consistent procedure in place during the audit period. We have addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure approvals are now documented appropriately prior to processing drawdowns.