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.
2022-007. 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.
2022-007. 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.
2022-007. 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.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-005. Finding: Inadequate Procedures for Ensuring Retention of Eligibility Documentation for the Upward Bound Program Federal Agency: U.S. Department of Education Assistance Listing Number: 84.047M Program Expenditures: $1,990,376 Program Name: TRIO ? Upward Bound Award Number(s): P047M170568 - 21 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not have adequate procedures in place to ensure the required documentation was retained for all students who received stipends during the audit period. During our testing of students who received stipends during the year under audit, we noted for 6 of 40 students (15%) students who received stipends totaling $1,405, the University did not maintain appropriate records to determine the students were eligible for the stipend received. The sample was not a statistically valid sample. Additionally, we noted for 5 of 40 students (12.5%) who participated in Upward Bound, the University did not maintain appropriate records to determine the students were eligible to participate in the Upward Bound program. The 5 students for which documentation was not maintained for eligibility to participate in Upward Bound are also included in the 6 students for which documentation was not maintained for eligibility to receive stipends. According to federal regulations (34 CFR 645.42), an Upward Bound project may provide stipends for full-time participants who show evidence of satisfactory participation in activities of the project. 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 the retention of documentation supporting participant eligibility. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency's activities. According to University officials, the missing documentation relates to a grant that is no longer funded and those responsible for retaining the documentation are no longer with the University. Without adequate documentation to support eligibility, there is a risk a student may improperly receive stipends or improperly be allowed to participate in the program. The University is also at risk of reduced funding in future years, as well as increased likelihood of program reviews from oversight agencies. (Finding Code No. 2022-005) RECOMMENDATION We recommend the University establish processes and procedures to ensure documentation is retained and retrievable when the parties responsible for the documentation leave the University. UNIVERSITY RESPONSE We agree we did not have adequate procedures to ensure the required documents were retained for all students who received stipends during the period tested. We will implement adequate controls to ensure document retention, including in instances where responsible staff have departed the University.
2022-008. Finding: Procurement Requirements Not Followed Federal Agency: U.S. Department of Education Assistance Listing Number: 84.425F Program Expenditures: $16,705,064 Program Name: Education Stabilization Fund Award Number(s): P425F200234 Questioned Costs: None The Southern Illinois University (University) Edwardsville campus did not follow procurement requirements for all purchases under the Higher Education Emergency Relief Fund (HEERF). During our testing of purchases made using institutional HEERF funds, we noted 1 out of 5 (20%) of transactions tested for procurement, purchased for $15,160, did not have documentation that procurement policies were followed. The sample was not a statistically valid sample. According to Uniform Guidance (2 CFR 200.320), the University must have and use documented procurement procedures, consistent with federal standards. Additionally, per Uniform Guidance (2 CFR 200.320), if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the University. The University?s procurement policy defines small purchases as those ranging from $10,001 to $99,000. Uniform Guidance (2 CFR 200.320) also allows for noncompetitive procurement, in which price or rate quotations are not required to be obtained from an adequate number of qualified sources, if certain circumstances apply, including the purchased item being available only from a single source. 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 procurement policies are followed. 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. The State Records Act (5 ILCS 160/8) requires records to be made and preserved containing adequate and proper documentation of decisions of the agency designed to furnish information to protect the legal and financial rights of the State and of persons directly affected by the agency?s activities. According to University officials, the department making the purchase does not typically receive funding subject to federal procurement requirements and therefore was unaware of the rules and regulations specific to purchases made with federal funds. Compliance with procurement policies helps ensure prudent use of federal funding. Failure to follow federal procurement regulations increases the likelihood of expenses being disallowed upon review by a federal agency and increases the risk of reduced funding in future years. (Finding Code No. 2022-008) RECOMMENDATION We recommend the University provide training to all departments with access to federal funding, specifically on the topic of procurement. UNIVERSITY RESPONSE We agree that procurement requirements were not followed for the identified purchases. Steps will be taken to reduce the risk of noncompliance going forward in instances where the procuring department may not regularly utilize grants funds for procurements.
Finding 2022-001: Reporting Requirements Program Name: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security - Assistance Listing No. 93.318 Awarding Agency: U.S. Department of Health and Human Services Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: None Context / Criteria: 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the non-federal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR Part 170 requires non-Federal entities making first-tier subawards of Federal funding to comply with the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FAFATA requires prime recipients, such as the Foundation, to report certain information about the sub-awards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition: The Foundation did not report required information about subawards made under Assistance Listing No. 93.185 and Assistance Listing No. 93.318 to the FSRS as required by FFATA within the timeline required. Cause / Effect: The Foundation lacks established internal controls to ensure accurate and timely sub-award information is reported to the FSRS. Recommendation: We recommend the Foundation develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Reporting Requirements Program Name: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security - Assistance Listing No. 93.318 Awarding Agency: U.S. Department of Health and Human Services Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: None Context / Criteria: 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the non-federal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR Part 170 requires non-Federal entities making first-tier subawards of Federal funding to comply with the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FAFATA requires prime recipients, such as the Foundation, to report certain information about the sub-awards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition: The Foundation did not report required information about subawards made under Assistance Listing No. 93.185 and Assistance Listing No. 93.318 to the FSRS as required by FFATA within the timeline required. Cause / Effect: The Foundation lacks established internal controls to ensure accurate and timely sub-award information is reported to the FSRS. Recommendation: We recommend the Foundation develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Reporting Requirements Program Name: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security - Assistance Listing No. 93.318 Awarding Agency: U.S. Department of Health and Human Services Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: None Context / Criteria: 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the non-federal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR Part 170 requires non-Federal entities making first-tier subawards of Federal funding to comply with the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FAFATA requires prime recipients, such as the Foundation, to report certain information about the sub-awards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition: The Foundation did not report required information about subawards made under Assistance Listing No. 93.185 and Assistance Listing No. 93.318 to the FSRS as required by FFATA within the timeline required. Cause / Effect: The Foundation lacks established internal controls to ensure accurate and timely sub-award information is reported to the FSRS. Recommendation: We recommend the Foundation develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Reporting Requirements Program Name: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security - Assistance Listing No. 93.318 Awarding Agency: U.S. Department of Health and Human Services Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: None Context / Criteria: 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the non-federal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR Part 170 requires non-Federal entities making first-tier subawards of Federal funding to comply with the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FAFATA requires prime recipients, such as the Foundation, to report certain information about the sub-awards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition: The Foundation did not report required information about subawards made under Assistance Listing No. 93.185 and Assistance Listing No. 93.318 to the FSRS as required by FFATA within the timeline required. Cause / Effect: The Foundation lacks established internal controls to ensure accurate and timely sub-award information is reported to the FSRS. Recommendation: We recommend the Foundation develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-002 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. The School Corporation did not have an internal control in place to review the underlying expenditures to determine if they were allowable in accordance with federal requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider which totaled $1,109,356 for the audit period. The School Corporation only reviewed a summary level invoice from the service provider which did not include the underlying support or detail of the reimbursable costs incurred by the service provider. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement a formal review of all expenditures incurred by the vendor by reviewing the underlying support for the expenditures incurred by the vendor. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-004 Information on the federal program: Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids (2) Proposals Section III ? Federal Award Findings and Questioned Costs (Continued) 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system enabled noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not perform a formal procurement when the School Corporation signed a contract with the service provider in July 2017. Additionally, the contract was extended in February 2019 through June 30, 2029 without a formal procurement process. The School Corporation did not have procedures in place to ensure the service provider was not debarred or suspended when the original contracts and amendments were signed. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure compliance with the grant agreement requirements and the procurement and suspension and debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. The School Corporation did not have an internal control in place to review the underlying expenditures to determine if they were allowable in accordance with federal requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider which totaled $1,109,356 for the audit period. The School Corporation only reviewed a summary level invoice from the service provider which did not include the underlying support or detail of the reimbursable costs incurred by the service provider. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement a formal review of all expenditures incurred by the vendor by reviewing the underlying support for the expenditures incurred by the vendor. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-004 Information on the federal program: Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids (2) Proposals Section III ? Federal Award Findings and Questioned Costs (Continued) 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system enabled noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not perform a formal procurement when the School Corporation signed a contract with the service provider in July 2017. Additionally, the contract was extended in February 2019 through June 30, 2029 without a formal procurement process. The School Corporation did not have procedures in place to ensure the service provider was not debarred or suspended when the original contracts and amendments were signed. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure compliance with the grant agreement requirements and the procurement and suspension and debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. The School Corporation did not have an internal control in place to review the underlying expenditures to determine if they were allowable in accordance with federal requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider which totaled $1,109,356 for the audit period. The School Corporation only reviewed a summary level invoice from the service provider which did not include the underlying support or detail of the reimbursable costs incurred by the service provider. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement a formal review of all expenditures incurred by the vendor by reviewing the underlying support for the expenditures incurred by the vendor. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-004 Information on the federal program: Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids (2) Proposals Section III ? Federal Award Findings and Questioned Costs (Continued) 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system enabled noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not perform a formal procurement when the School Corporation signed a contract with the service provider in July 2017. Additionally, the contract was extended in February 2019 through June 30, 2029 without a formal procurement process. The School Corporation did not have procedures in place to ensure the service provider was not debarred or suspended when the original contracts and amendments were signed. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure compliance with the grant agreement requirements and the procurement and suspension and debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources and a contract must be entered into when the total cost exceeds $50,000. The School Corporation did not enter into contracts with vendors for purchases in excess of $50,000 as required by state statute for three of the six vendors tested. As a result, the School Corporation did not verify that these vendors were not excluded or disqualified from participation in federal assistance programs or activities. In addition to the three vendors noted above, the School Corporation did not verify that vendors with contracts over $25,000 were not excluded or disqualified from participation in federal award programs for fiscal year 2021-2022. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 WARSAW COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) (Uniform Guidance) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.318(a) (Revised Uniform Guidance) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must confirm to the procurement standards identified in ?? 200.317 through 200.327." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: INDIANA STATE BOARD OF ACCOUNTS 17 WARSAW COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not established a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources and a contract must be entered into when the total cost exceeds $50,000. The School Corporation did not enter into contracts with vendors for purchases in excess of $50,000 as required by state statute for three of the six vendors tested. As a result, the School Corporation did not verify that these vendors were not excluded or disqualified from participation in federal assistance programs or activities. In addition to the three vendors noted above, the School Corporation did not verify that vendors with contracts over $25,000 were not excluded or disqualified from participation in federal award programs for fiscal year 2021-2022. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 WARSAW COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) (Uniform Guidance) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.318(a) (Revised Uniform Guidance) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must confirm to the procurement standards identified in ?? 200.317 through 200.327." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: INDIANA STATE BOARD OF ACCOUNTS 17 WARSAW COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not established a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.