Finding Number: 2022-SA2 Material Weakness – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Period of Performance, Program Income, Reporting, Special Tests – Compliance and Control Finding - Internal Control over Compliance Federal Award: No. 64.024 VA Homeless Providers Grant and Per Diem Program Federal Agency: U.S. Veterans Administration Pass-Through Entity: Not applicable Repeat Finding: Yes – 2021-SA2 Criteria or Specific Requirement: 2 CFR section 200.303a states the non-Federal must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, 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: The Organization did not maintain effective internal controls over compliance over direct and material compliance areas. Cause: Factors beyond the control of current management, including poorly designed policies and procedures and lack of understanding of Federal award requirements and training, as key members of the accounting department left the Organization before appropriately transferring knowledge and records related to the Federal awards. Effect or Potential Effect: Potential for noncompliance of direct and material audit requirements. Questioned Costs: Related questioned costs are unknown. Context: These issues stem from policies and procedures established by former key accounting personnel, predate current management’s oversight, and were therefore outside their direct control. Recommendation: Organization should implement appropriate internal controls over compliance for all direct and material compliance areas. View of Responsible Officials: In response to Finding No. 2022-SA2, management agrees with the finding. Corrective actions were implemented in subsequent fiscal years. CFDA numbers for new federal awards are identified, along with the applicable compliance requirements in accordance with the OMB Compliance Supplement (Matrix of Federal Compliance Requirements). Policies and procedures have been established for each applicable compliance requirement and are communicated to employees responsible for monitoring and ensuring compliance.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: During the audit, we noted that a physical inventory of the School’s property had not been taken and reconciled with the property records within the last two years. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There was turnover in the School’s key accounting staff. Effect: Property records may not be accurate and proper custodianship of the property is compromised. Questioned Costs: N/A - No questioned costs were identified because the finding relates to property inventory and reconciliation procedures rather than specific unsupported or unallowable federal expenditures. Repeat Finding: Yes, 2021-004. Recommendation: We recommend that the School develop policies and procedures requiring a physical inventory of the School’s property at least once every two years, and reconcile the results of the inventory to the property records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. During the review of the School’s procurement policies, the following was noted: • Any purchase of materials, supplies, or equipment having a purchase price exceeding $5,000 shall be purchased only after having requested at least three bids or as needed, advertised for sealed bids for a period of not less than five (5) days. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension”, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: During testing the following was noted: • 1 of 1 Individually Important Items tested did not have bidding documentation or sole source justification. • 2 of 2 samples tested did not have bidding documentation or sole source justification. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The School was not following its policies for purchases that exceed $5,000. Effect: The School could be overpaying for services or items that could be obtained elsewhere for less. Questioned Costs: Known – $35,010. Repeat Finding: Yes, 2021-005. Recommendation: We recommend that the School follow its written procurement policies and maintain proper supporting documentation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Per the compliance supplement: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFR part 63), as the Indian tribe or tribal organization establishes. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: For 1 of the 3 samples selected for testing, the School did not provide support for review and approval of the Character Investigations. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: Lack of internal controls and management oversight. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Questioned Costs: N/A - No questioned costs were identified because the finding relates to the lack of documented review and approval of character investigations rather than specific unsupported or unallowable federal expenditures. Repeat Finding: Yes, 2021-007. Recommendation: We recommend that the School establish effective internal controls for the Character Investigations compliance requirement and adhere to the internal controls. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Per the compliance supplement: A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: For 3 of the 3 samples selected for testing, the School did not provide support for review and approval of the monthly bank reconciliations. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: Lack of internal controls and management oversight. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Questioned Costs: N/A - No questioned costs were identified because the finding relates to the lack of documented review and approval of monthly bank reconciliations rather than specific unsupported or unallowable federal expenditures. Repeat Finding: No. Recommendation: We recommend that the School establish effective internal controls for the monthly bank reconcialtions and adhere to the internal controls. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
2022-001 Improve Document Retention and Evidence of Supervisory Review and Approvals Federal Agency: U.S. Department of Education Award Name: COVID-19 – Education Stabilization Fund AL Number(s): 84.425D/U Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement In accordance with 2 CFR §200.303, non-Federal entities receiving Federal awards must establish and maintain effective internal controls over Federal programs that provide reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective controls over payroll expenditures and vendor disbursements should include documented supervisory review and approval of payroll authorizations, invoices, and warrants prior to payment and retention of supporting documentation. Condition and Context During testing of ESSER expenditures, the following exceptions were identified: Payroll Testing Of 10 employee payroll transactions tested, payroll authorization forms supporting the salary rates charged to the ESSER program were provided; however, none of the forms contained evidence of supervisory or management approval of the rates paid. Accounts Payable Testing Of 15 vendor expenditures tested: • 7 invoices lacked evidence of review and approval prior to payment. • 3 invoices could not be located and were not provided for audit. • 13 related warrants could not be provided to support payment authorization and approval. Cause Management did not maintain or consistently operate internal controls designed to ensure that payroll rate authorizations, vendor invoices, and payment warrants were reviewed, approved, and retained in accordance with recordkeeping requirements. In addition, controls over document retention were not operating effectively. Effect or Potential Effect Without evidence of approval and supporting documentation, the Town cannot demonstrate that payroll and vendor expenditures charged to the ESSER program were properly authorized, accurately calculated, and supported. As a result, there is an increased risk that unallowable, inaccurate, or unauthorized expenditures could be charged to the Federal program and remain undetected. Questioned Costs No questioned costs are reported as they are below the questioned costs threshold of $25,000. Recommendation The Town should strengthen internal controls over compliance for Federal programs by requiring documented approval of all payroll rate authorizations before employees are compensated from Federal awards, require evidence of review and approval on all invoices prior to payment, and maintain complete supporting documentation, including invoices and warrants, in accordance with Federal record retention requirements. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR 200.334 requires the retention of records and supporting documentation to demonstrate eligibility determinations and allowability of expenditures under the program. Condition and Context During our audit, we tested a sample of 40 selections for allowable costs, as well as a sample of 40 for individual eligibility determinations under the program in which 35 selections were leveraged between the two tests. For 1 of the items selected for testing under allowable cost compliance and eligibility requirements, the County was unable to provide some of the required supporting documentation to demonstrate that individuals met the program’s eligibility requirements. However, lease agreements supporting the amount ultimately paid to the individual were provided to support allowability. The documentation was retained in an online portal to which the County no longer had access at the time of our audit procedures. Cause The County did not establish sufficient procedures or controls to ensure ongoing access to required supporting documentation maintained in the external portal used for program administration. Effect or Potential Effect Due to the weakness in internal controls noted above, the County could not demonstrate compliance with eligibility requirements for the sampled transactions. This also constitutes noncompliance with record retention requirements and impairs the ability for sufficient procedures to be performed over the program. Questioned Costs None reported. Recommendation The County should implement policies and procedures to ensure required documentation for the program is retained in a manner that ensures continued access, even if administration platforms change or external portals are no longer accessible. The County should also periodically verify that it retains all necessary support for program transactions as required under federal regulations. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Program guidance requires timely and accurate submission of quarterly financial and performance reports, as well as monthly performance reports, to the U.S. Department of the Treasury in accordance with established deadlines. Condition and Context During our testing of the reporting compliance requirement for ERA 1 and ERA 2 awards over the quarterly financial reports, quarterly performance reports and monthly performance reports, we noted the following exceptions: • Of the 2 quarterly financial reports (SF-425) tested, both the ERA 1 and ERA 2 reports for quarter end 9/30/2021 were submitted on 12/31/2021 after the required deadline of 10/29/2021. The County indicated the late submissions were due to the inability to retrieve the information required to compile the reports due to an ERAP system error. • Of the 4 monthly performance reports tested, the County was unable to provide documentation showing the date of submission for the ERA 1 and ERA 2 reports for the month of October 2021. The remaining 2 monthly performance reports for the month of April 2022 were submitted in July 2022, and no approved extension was on file. • Of the 2 quarterly performance reports tested, the ERA 1 report for quarter end 9/30/2021 was submitted on 12/31/2021 after the required deadline of 10/29/2021 due to the inability to retrieve the information required to compile the reports due to an ERA system error. The other quarterly performance report tested for ERA 2 for the quarter ending 6/30/2022 was not submitted on time as evidence by a notification email from Treasury after the due date had passed. Cause The County did not establish sufficient procedures or controls to ensure timely submission of all required reports or retention of sufficient evidence to support timeliness of filing. In addition, the County did not have a contingency process in place to address system errors affecting timely reporting. Effect or Potential Effect Due to the weakness in internal controls noted above, there is an increased risk that required program information may not be reported to the granting agency in a timely manner consistent with federal reporting requirements. Additionally, the lack of supporting documentation impedes the ability to verify compliance with reporting deadlines. No questioned costs are reported as the requirement is procedural in nature. Questioned Costs None reported. Recommendation The County should strengthen internal controls in place over the timely submission and documentation of required reports for the program. This should include maintaining sufficient evidence of the date and method of submission and considering the implementation of backup procedures in the event system issues affect timely reporting. The County should ensure any delays are documented and, if necessary, approved by the granting agency in writing. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
U.S. Department of Homeland Security Pass-through Entity: North Carolina Department of Public Safety, Division of Emergency Management Program Name: Disaster Grants – Public Assistance Federal Assistance Listing Number 97.036 Significant Deficiency, Nonmaterial Noncompliance – Reporting Finding 2022-006 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per 2 CFR 200.334 the recipient must retain all federal award records for three years from the date of submission of their final financial report. Condition: During the audit, we tested ten reports and noted the following: a) There were 10 instances out of 10 reports tested where the Town was unable to provide evidence that the reports were reviewed prior to submission. b) There were 5 instances out of 10 reports tested where the Town submitted the reports after the due date. Questioned Costs: None. Effect: The absence of documented review controls increase the risk that reports may contain errors or omissions that are not detected prior to submission, and reports may be submitted late, resulting in potential noncompliance with federal reporting requirements. Cause: The Town did not have a formal policy or practice to ensure documentation was retained to evidence review and submission of all reports. Recommendation: The Town should ensure these policies and best practices are adhered to ensure all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Management Response: Management agrees with the findings and is implementing corrective procedures, which are further discussed in the corrective action plan.
ALN and Title: 21.027 Coronavirus State and Local Fiscal Recovery Fund Federal Agency: U.S. Department of the Treasury Award Year: 2021 Condition: The City did not implement controls over reviewing vendors for suspension and debarment actions prior to entering into covered transactions. Criteria: 2 CFR 200.303(a) requires that Non-Federal entities receiving federal awards must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the Non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms of conditions of the Federal award. In addition, Non-Federal entities are subject to the regulations in 2 CFR 180, which restrict the City from entering into covered transactions for the purchase of goods or services with an entity that is suspended, debarred, or otherwise excluded from Federal contracting. Questioned Costs: None noted. Effect: The lack of controls around review of vendors for suspsension and debarment could result in contracts that are entered into with vendors who have been suspended or otherwise excluded from Federal contracting and are not eligible to participate in contracts paid from Federal funds. The costs of such contracts may be disallowed by Federal agencies, and other actions, including grant termination or suspension proceedings, can result. Cause: There is a lack of formal processes and policies in place to ensure compliance with the federal regulations that govern the City’s grants. Auditor’s Recommendation: The auditor recommends that the City implement formal processes to ensure compliance with federal regulations and grant requirements, including policies and procedures to document the review of vendors prior to engaging in contracts, for suspension and debarement. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and acknowledges that while the City was verifying that vendors were not on the suspended or debarred listing, a formal documentation process was not in place to evidence that these verifications were completed prior to awarding contracts funded with federal awards. To address this finding, the City will retain documentation of all suspension and debarment checks (e.g., screenshots or system confirmations from SAM.gov) as part of the procurement file to demonstrate compliance with federal requirements. Responsible Official: Grant Administrator Anticipated Completion Date: June 30, 2027
Finding 2022 ? 001 Subject: Coronavirus Relief Funds ? internal controls Federal Agency: Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds, Coronavirus Relief Fund ALN: 21.019, 21.027 Federal Award numbers and Years (or other identifying numbers): 2020-2021, 2021-2022 Pass-Through Entity: Chicago Bar Foundation Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit finding: Material Weakness Condition An effective internal control system was not in place at the Center for Conflict Resolution in order to ensure compliance with requirements related to the grant agreements and the compliance requirements listed above. Technology expense requested for reimbursement was not actually expended prior to requesting reimbursement in May 2022 in the amount of $95,000. Center for Conflict Resolution recorded the expenditure in May 2022 but did not actually release the check until July 2022 and did not sign the contract until June 2022. Upon identifying the issue, Center for Conflict Resolution was informed, and they reissued a revised May reimbursement request, excluding the held check, and included the expenditure in the July 2022 reimbursement request. The Chicago Bar Foundation is 3 months behind on reimbursements to Center for Conflict Resolution and as such the amount has not been reimbursed as of the date of the audit. Context The lack of internal controls was an isolated issue within the audit period and only affected one expenditure in the last month of the audit period. Criteria `The auditee shall: . . . (b) Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Center for Conflict Resolution?s management had not developed or implemented an effective system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect The failure to establish an effective internal control system placed Center for Conflict Resolution at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of internal controls pertaining to the expenditures and reimbursement requests could have 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. Recommendation We recommended that the Center for Conflict Resolution's management establish controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. 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: Coronavirus Relief Funds ? internal controls Federal Agency: Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds, Coronavirus Relief Fund ALN: 21.019, 21.027 Federal Award numbers and Years (or other identifying numbers): 2020-2021, 2021-2022 Pass-Through Entity: Chicago Bar Foundation Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit finding: Material Weakness Condition An effective internal control system was not in place at the Center for Conflict Resolution in order to ensure compliance with requirements related to the grant agreements and the compliance requirements listed above. Technology expense requested for reimbursement was not actually expended prior to requesting reimbursement in May 2022 in the amount of $95,000. Center for Conflict Resolution recorded the expenditure in May 2022 but did not actually release the check until July 2022 and did not sign the contract until June 2022. Upon identifying the issue, Center for Conflict Resolution was informed, and they reissued a revised May reimbursement request, excluding the held check, and included the expenditure in the July 2022 reimbursement request. The Chicago Bar Foundation is 3 months behind on reimbursements to Center for Conflict Resolution and as such the amount has not been reimbursed as of the date of the audit. Context The lack of internal controls was an isolated issue within the audit period and only affected one expenditure in the last month of the audit period. Criteria `The auditee shall: . . . (b) Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Center for Conflict Resolution?s management had not developed or implemented an effective system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect The failure to establish an effective internal control system placed Center for Conflict Resolution at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of internal controls pertaining to the expenditures and reimbursement requests could have 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. Recommendation We recommended that the Center for Conflict Resolution's management establish controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Institutions are required to be both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of Higher Education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition While without funding for the period, for the calendar quarters ended September 30, 2021 and March 31, 2022, a quarterly report for the Student Aid Portion was not posted. For the calendar quarter ended June 30, 2021, the quarterly report for the Student Aid Portion and Institutional Portion was not submitted within the required 10 days of the quarter end. For the calendar quarter ended September 30, 2021, the quarterly report for the Institutional Portion was not submitted within the required 10 days of the quarter end. Rather the reports were submitted within 15 and 12 days, respectively, of the quarter end. For the calendar quarters ended June 30, 2021 and December 31, 2021, the information reported on the Student Aid Portion quarterly reports for three of the four key line items, was not accurate. The three key line items included total amount distributed to students, number of students that were eligible, and number of students that received a distribution. For the quarter ended June 30, 2021, the total amount distributed to students was inaccurate by $118,403 and the number of students that were eligible and number of students that received a distribution were inaccurate by 13 students. For the quarter ended December 31, 2021, the total amount distributed to students was inaccurate by $21,134 and the number of students that were eligible and number of students that received a distribution were inaccurate by 167 students. Cause and Effect Management?s review control over its reporting requirements for HEERF was not operating at a level of precision to ensure timely and accurate reporting. Therefore, certain required reporting was not posted publicly or submitted, was not submitted timely, or was not accurate. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Institutions are required to be both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of Higher Education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition While without funding for the period, for the calendar quarters ended September 30, 2021 and March 31, 2022, a quarterly report for the Student Aid Portion was not posted. For the calendar quarter ended June 30, 2021, the quarterly report for the Student Aid Portion and Institutional Portion was not submitted within the required 10 days of the quarter end. For the calendar quarter ended September 30, 2021, the quarterly report for the Institutional Portion was not submitted within the required 10 days of the quarter end. Rather the reports were submitted within 15 and 12 days, respectively, of the quarter end. For the calendar quarters ended June 30, 2021 and December 31, 2021, the information reported on the Student Aid Portion quarterly reports for three of the four key line items, was not accurate. The three key line items included total amount distributed to students, number of students that were eligible, and number of students that received a distribution. For the quarter ended June 30, 2021, the total amount distributed to students was inaccurate by $118,403 and the number of students that were eligible and number of students that received a distribution were inaccurate by 13 students. For the quarter ended December 31, 2021, the total amount distributed to students was inaccurate by $21,134 and the number of students that were eligible and number of students that received a distribution were inaccurate by 167 students. Cause and Effect Management?s review control over its reporting requirements for HEERF was not operating at a level of precision to ensure timely and accurate reporting. Therefore, certain required reporting was not posted publicly or submitted, was not submitted timely, or was not accurate. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-005: Reporting Federal Agency U.S. Department of Health and Human Services Federal Programs COVID-19 ? Provider Relief Fund (CFDA 93.498) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Criteria The Provider Relief Fund (PRF) reporting portal should be accurate, including the line item Total Other Provider Relief Fund Expenses. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The University submitted their PRF period one portal reporting on September 30, 2021 which reflected $114,692,613 of Lost Revenues and $14,854,235 of Other Provider Relief Fund Expenses. An amended PRF period one portal reporting was submitted on June 27, 2022 which reflected lost revenues of $114,692,613 and $0 of Other Provider Relief Fund Expenses. The amended period one portal reporting was filed after the due date. Cause and Effect Management?s review control over its reporting requirements for PRF was not operating at a level of precision to initially ensure its accuracy. When management identified an amended report was required, the update to the portal reporting was not made timely. Management did identify and correct the reporting. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over the reporting requirements with an emphasis on making timely updates, as necessary. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-001: Enrollment Reporting Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P063P211285 Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student?s interest subsidy and initiation of repayment periods. Per the NSLDS Enrollment Guide section 4.4.2, the NSLDS has defined the effective date, for both program level and campus level reporting, to be significant data elements. The NSLDS Enrollment Guide states that the effective date for a withdrawal status should be the final day of the term in which the student was last enrolled. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 1 out of 40 students, the student had graduated but the status change was not reported at the campus level or at the program level. For 1 out of 40 students, the student had graduated but the status change was not reported at the program level. For 14 out of 40 students, the effective date of the students? withdrawal status per the program level reporting did not agree to student withdrawal status? effective date per campus level reporting. The campus level effective date was the last day of the Fall semester and the program level effective date was the first day of Spring semester. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the program level and campus level enrollment reporting submissions. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-001: Enrollment Reporting Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P063P211285 Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student?s interest subsidy and initiation of repayment periods. Per the NSLDS Enrollment Guide section 4.4.2, the NSLDS has defined the effective date, for both program level and campus level reporting, to be significant data elements. The NSLDS Enrollment Guide states that the effective date for a withdrawal status should be the final day of the term in which the student was last enrolled. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 1 out of 40 students, the student had graduated but the status change was not reported at the campus level or at the program level. For 1 out of 40 students, the student had graduated but the status change was not reported at the program level. For 14 out of 40 students, the effective date of the students? withdrawal status per the program level reporting did not agree to student withdrawal status? effective date per campus level reporting. The campus level effective date was the last day of the Fall semester and the program level effective date was the first day of Spring semester. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the program level and campus level enrollment reporting submissions. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-003: Loan Disbursement Notifications Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285 Criteria Per 34 CFR section 668.165, if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent, no earlier than 30 days before the disbursement and no later than 30 days after the disbursement, in writing of the anticipated date and amount of the loan disbursement, the student?s right or parent?s right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 28 out of 40 students, the federal direct loan disbursement notification was not sent to the student or parent within the required 30 days before or 30 days after the disbursement was credited to the student?s account. Cause and Effect The University?s internal controls for determining that a loan disbursement notification was sent timely for each disbursement made were not operating effectively. Accordingly, the University did not send a loan notification for disbursements within the required timeframe. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the controls over loan disbursements to ensure that all loan disbursements through the Federal Direct Student Loan Program have a written notification sent to the student and/or parents within the required timeline of within 30 days before and 30 days after the disbursement date. Views of Responsible Officials: See management?s corrective action plan.
2022-003 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: June 01, 2021 through May 31, 2022 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted the student, institutional, and annual reports did not have documentation of their review prior to submission. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The College did not have a process in place to ensure reports were reviewed and documentation of review was maintained. Effect: The College did not comply with ED regulations by retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: June 01, 2021 through May 31, 2022 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted the student, institutional, and annual reports did not have documentation of their review prior to submission. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The College did not have a process in place to ensure reports were reviewed and documentation of review was maintained. Effect: The College did not comply with ED regulations by retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: June 01, 2021 through May 31, 2022 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted the student, institutional, and annual reports did not have documentation of their review prior to submission. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The College did not have a process in place to ensure reports were reviewed and documentation of review was maintained. Effect: The College did not comply with ED regulations by retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization did not complete the indirect costs section of the annual Federal Financial Report submitted during the fiscal year. Auditor noted a total of $74,062 was drawn in indirect costs for fiscal year 2022. ? The Organization is not reporting the action in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-003 Recommendation: ? We recommend the Organization review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. ? Specific to special reports for FFATA, we recommend the Organization provide training on the requirements to those employees responsible for reporting the action in FSRS. Views of responsible officials: The Organization was unaware of the FFATA reporting requirement. The Organization will register and submit the FFATA. Also, the Organization failed to report the indirect costs on the FFR. The Organization has notified the responsible parties to avoid future occurrences. The FFR?s have been completed to report indirect costs separately in fiscal year 2023. The FFATA was submitted in fiscal year 2023 and will be updated yearly.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: $1,062,184 Context: During our testing, we noted the following exception: ? The Organization did not reduce the PRF expenses claimed by the amounts reimbursed by Medicare through the cost report. Auditor calculated the average amount reimbursed by MCR and noted an average MCR reimbursement rate of 26.8% and 28.1% in fiscal years 2021 and 2020, respectively. The calculated total of costs reimbursed by Medicare through the cost report is $1,062,184. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: No. Recommendation: We recommend the Organization evaluate its financial reporting processes and controls to determine whether additional controls over the preparation of any Provider Relief Fund reports are needed to ensure the reports are prepared in line with the Provider Relief Fund guidelines. Views of responsible officials: The Organization missed reducing the costs claimed against PRF by the amounts reimbursed through the Medicare cost report. The Organization did have additional lost revenues though that would offset these costs claimed and wouldn?t result in a repayment of the funds. We would look to HRSA for guidance on how you would like us to update our Phase 1 PRF report or how you would like to see this corrected. Also, the CFO will listen to webinars to receive education for Phase IV funds that were received by the Organization to ensure compliance with the reporting requirements.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Perkins Loan Program, Assistance Listing Number (ALN) 84.038 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2021-2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the Pell grant and U.S. Department of Education loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by the U.S. Department of Education via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. NSLDS Enrollment Reporting Guide Chapter 4.4.5: If the student enrolls in the summer term (or other non-required terms) at least half time, the student?s actual summer enrollment status is reported. If such a student subsequently withdraws from the summer term, the student?s most recent enrollment status of half time or greater should be reported throughout the remainder of the summer. If the student does not return in the fall as expected, the status must be changed to ?Withdrawn? with the date the student withdrew from the summer term as the Enrollment Status Effective Date. Condition: The University did not accurately or timely report student status changes to the NSLDS for 6 of 60 students selected for testing. Questioned costs: $0 Context: EY selected and tested 60 students from the combined population of 3,575 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2022. The 60 students, randomly selected, consisted of 23 student graduates, 23 student withdrawals/no shows, and 14 student changes in attendance levels. Of the 23 student graduates selected, one graduate was not reported to NSLDS as graduated. Of the 23 withdrawals/no shows, two withdrawals were reported after the 60-day reporting requirement. The withdrawals were reported to NSLDS 70 and 69 days after the respective withdrawal dates. Additionally, for three of the 23 withdrawals/no shows, the withdrawals were inaccurately reported to NSLDS because the withdrawals occurred in the Summer semester with the students previously enrolled in the Spring and registered in the Fall. Of the 14 student changes in attendance levels, all were reported accurately and timely by the University. Effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Identification as a repeat finding, if applicable: Yes ? 2021-001; 2020-001; 2019-002. Recommendation: The University should review and revise its internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.
Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Perkins Loan Program, Assistance Listing Number (ALN) 84.038 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2021-2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the Pell grant and U.S. Department of Education loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by the U.S. Department of Education via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. NSLDS Enrollment Reporting Guide Chapter 4.4.5: If the student enrolls in the summer term (or other non-required terms) at least half time, the student?s actual summer enrollment status is reported. If such a student subsequently withdraws from the summer term, the student?s most recent enrollment status of half time or greater should be reported throughout the remainder of the summer. If the student does not return in the fall as expected, the status must be changed to ?Withdrawn? with the date the student withdrew from the summer term as the Enrollment Status Effective Date. Condition: The University did not accurately or timely report student status changes to the NSLDS for 6 of 60 students selected for testing. Questioned costs: $0 Context: EY selected and tested 60 students from the combined population of 3,575 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2022. The 60 students, randomly selected, consisted of 23 student graduates, 23 student withdrawals/no shows, and 14 student changes in attendance levels. Of the 23 student graduates selected, one graduate was not reported to NSLDS as graduated. Of the 23 withdrawals/no shows, two withdrawals were reported after the 60-day reporting requirement. The withdrawals were reported to NSLDS 70 and 69 days after the respective withdrawal dates. Additionally, for three of the 23 withdrawals/no shows, the withdrawals were inaccurately reported to NSLDS because the withdrawals occurred in the Summer semester with the students previously enrolled in the Spring and registered in the Fall. Of the 14 student changes in attendance levels, all were reported accurately and timely by the University. Effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Identification as a repeat finding, if applicable: Yes ? 2021-001; 2020-001; 2019-002. Recommendation: The University should review and revise its internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.
Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Perkins Loan Program, Assistance Listing Number (ALN) 84.038 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2021-2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the Pell grant and U.S. Department of Education loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by the U.S. Department of Education via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. NSLDS Enrollment Reporting Guide Chapter 4.4.5: If the student enrolls in the summer term (or other non-required terms) at least half time, the student?s actual summer enrollment status is reported. If such a student subsequently withdraws from the summer term, the student?s most recent enrollment status of half time or greater should be reported throughout the remainder of the summer. If the student does not return in the fall as expected, the status must be changed to ?Withdrawn? with the date the student withdrew from the summer term as the Enrollment Status Effective Date. Condition: The University did not accurately or timely report student status changes to the NSLDS for 6 of 60 students selected for testing. Questioned costs: $0 Context: EY selected and tested 60 students from the combined population of 3,575 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2022. The 60 students, randomly selected, consisted of 23 student graduates, 23 student withdrawals/no shows, and 14 student changes in attendance levels. Of the 23 student graduates selected, one graduate was not reported to NSLDS as graduated. Of the 23 withdrawals/no shows, two withdrawals were reported after the 60-day reporting requirement. The withdrawals were reported to NSLDS 70 and 69 days after the respective withdrawal dates. Additionally, for three of the 23 withdrawals/no shows, the withdrawals were inaccurately reported to NSLDS because the withdrawals occurred in the Summer semester with the students previously enrolled in the Spring and registered in the Fall. Of the 14 student changes in attendance levels, all were reported accurately and timely by the University. Effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Identification as a repeat finding, if applicable: Yes ? 2021-001; 2020-001; 2019-002. Recommendation: The University should review and revise its internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.
Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF), ALN 84.425 (F/L) Award year: 2021-2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318 (i) General Procurement Standards states, ?the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.319 (e) Competition states, ?the non-Federal entity must ensure that all prequalified lists of persons, firms, or products which are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, the non-Federal entity must not preclude potential bidders from qualifying during the solicitation period.? The University of Incarnate Word?s Procurement and Bid Policy Version 1.0, Preferred Vendors, states ?Preferred vendors have been identified by the University?s Purchasing Department as providing fair and economical pricing on the goods or services that they provide; therefore, the University has decided to frequently utilize these vendors for purchasing needs. Goods or services purchased from a preferred vendor do not have to go through the bid process. A preferred vendor listing is maintained by the Purchasing Department which is available on the Policy website. Departments can submit justification to assign a vendor as preferred; however, the Director of Purchasing has ultimate discretion over the classification. All preferred vendors are formally reviewed annually by the Purchasing Department to assess whether they continue to provide the University with pricing that is within range or better than competitors. A sample of regularly purchased items is selected and the pricing from the preferred vendor is compared to the pricing of a few competitors to determine whether the preferred vendor is providing comparable pricing. Documentation of the annual pricing review is retained to justify the vendors being included on the preferred vendor listing.? Condition: The University did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, as required by the University?s Procurement and Bid Policy, the University did not maintain and provide documentation of the performance of an annual pricing review in order to assess whether preferred vendors continue to provide comparable pricing to other vendors. Questioned costs: $0 Context: EY selected and tested six procurements with expenditures totaling $1.1 million from a population of 23 procurements with expenditures totaling $2 million charged to the HEERF program during the year ended May 31, 2022. Of the six procurements tested: ? According to the University, two procurements were made from a preferred vendor included on a preferred vendor list; however, the history of the procurement was not documented, including the decision to use a preferred vendor for the procurement. Additionally, there was no evidence that the preferred vendor was reviewed to ensure comparable pricing. ? Three procurements were made from a single vendor using noncompetitive procurement ? sole source. A sole source justification memo was prepared; however, the memo did not address the history of the procurement and the reasons for lack of solicitation of other vendors in sufficient detail. ? According to the University, one procurement was made from a vendor using noncompetitive procurement ? public emergency; however, the history of the procurement and the emergency procurement were not documented. Effect: The University did not comply with the general procurement standards per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. Additionally, if the University does not review and document the review of preferred vendors for comparable pricing on a periodic basis, noncompliance with federal competitive procurement requirements could occur. Cause: The University did not have effective internal controls and procedures in place to ensure the University maintained records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement and other required elements. Identification as a repeat finding, if applicable: Not Applicable. Recommendation: The University should retain written documentation for procurements documenting the history of the procurement prior to the procurement of goods or services, including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The University should perform and maintain documentation of pricing reviews for preferred vendors to ensure continued comparable pricing and maximum open and free competition. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.
Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF), ALN 84.425 (F/L) Award year: 2021-2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318 (i) General Procurement Standards states, ?the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.319 (e) Competition states, ?the non-Federal entity must ensure that all prequalified lists of persons, firms, or products which are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, the non-Federal entity must not preclude potential bidders from qualifying during the solicitation period.? The University of Incarnate Word?s Procurement and Bid Policy Version 1.0, Preferred Vendors, states ?Preferred vendors have been identified by the University?s Purchasing Department as providing fair and economical pricing on the goods or services that they provide; therefore, the University has decided to frequently utilize these vendors for purchasing needs. Goods or services purchased from a preferred vendor do not have to go through the bid process. A preferred vendor listing is maintained by the Purchasing Department which is available on the Policy website. Departments can submit justification to assign a vendor as preferred; however, the Director of Purchasing has ultimate discretion over the classification. All preferred vendors are formally reviewed annually by the Purchasing Department to assess whether they continue to provide the University with pricing that is within range or better than competitors. A sample of regularly purchased items is selected and the pricing from the preferred vendor is compared to the pricing of a few competitors to determine whether the preferred vendor is providing comparable pricing. Documentation of the annual pricing review is retained to justify the vendors being included on the preferred vendor listing.? Condition: The University did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, as required by the University?s Procurement and Bid Policy, the University did not maintain and provide documentation of the performance of an annual pricing review in order to assess whether preferred vendors continue to provide comparable pricing to other vendors. Questioned costs: $0 Context: EY selected and tested six procurements with expenditures totaling $1.1 million from a population of 23 procurements with expenditures totaling $2 million charged to the HEERF program during the year ended May 31, 2022. Of the six procurements tested: ? According to the University, two procurements were made from a preferred vendor included on a preferred vendor list; however, the history of the procurement was not documented, including the decision to use a preferred vendor for the procurement. Additionally, there was no evidence that the preferred vendor was reviewed to ensure comparable pricing. ? Three procurements were made from a single vendor using noncompetitive procurement ? sole source. A sole source justification memo was prepared; however, the memo did not address the history of the procurement and the reasons for lack of solicitation of other vendors in sufficient detail. ? According to the University, one procurement was made from a vendor using noncompetitive procurement ? public emergency; however, the history of the procurement and the emergency procurement were not documented. Effect: The University did not comply with the general procurement standards per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. Additionally, if the University does not review and document the review of preferred vendors for comparable pricing on a periodic basis, noncompliance with federal competitive procurement requirements could occur. Cause: The University did not have effective internal controls and procedures in place to ensure the University maintained records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement and other required elements. Identification as a repeat finding, if applicable: Not Applicable. Recommendation: The University should retain written documentation for procurements documenting the history of the procurement prior to the procurement of goods or services, including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The University should perform and maintain documentation of pricing reviews for preferred vendors to ensure continued comparable pricing and maximum open and free competition. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Common Origination and Disbursement (COD) System (OMB No. 1845-0039) - All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Schools submit Pell origination records and disbursement records to the COD System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition Found, Including Perspective We identified 12 students in a sample of 40 that had Pell disbursements that were reported to the COD System after the required 15 day deadline (on average 26 days). Cause and Possible Asserted Effect Management?s control over reporting Pell disbursement data to the COD System timely did not operate effectively. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample.Repeat finding The audit finding is not a repeat of a finding in the immediately prior fiscal year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting of Pell disbursement data to the COD System within the required timeframe. Views of Responsible Officials Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. The financial aid office has implemented reporting safeguards, including a secondary review of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.
Criteria: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards 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 awards. In addition, 2 CFR section 200.403 requires that costs be adequately documented, among other criteria, to be allowable under federal awards. Condition: For 8 of 60 transactions tested, Orlando Shakespeare Theater, Inc. (the “Organization”) was unable to provide supporting documentation evidencing that the expenditure was incurred, allowable and within the period of performance of the Organization’s Shuttered Venue Operators Grant. The sample was not intended to be, and was not, a statistically valid sample. Cause: The inability to maintain appropriate supporting documentation was due to employee turnover during the pandemic and a lack of formal policies and procedures over expenditures incurred during a previously unforeseen time of remote working during the COVID-19 global pandemic. Effect or Potential Effect: Certain costs incurred by the Organization may be unallowable or outside the period of performance of the grant resulting in noncompliance and possible questioned costs. Recommendation: We recommend that the Organization implement policies, processes and internal controls surrounding expenditures and validate that adequate supporting documentation, including invoices and payment support, is maintained by the Organization to support compliance with grant requirements.
Finding 2022 ? 001 Subject: Coronavirus Relief Funds ? internal controls Federal Agency: Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds, Coronavirus Relief Fund ALN: 21.019, 21.027 Federal Award numbers and Years (or other identifying numbers): 2020-2021, 2021-2022 Pass-Through Entity: Chicago Bar Foundation Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit finding: Material Weakness Condition An effective internal control system was not in place at the Center for Conflict Resolution in order to ensure compliance with requirements related to the grant agreements and the compliance requirements listed above. Technology expense requested for reimbursement was not actually expended prior to requesting reimbursement in May 2022 in the amount of $95,000. Center for Conflict Resolution recorded the expenditure in May 2022 but did not actually release the check until July 2022 and did not sign the contract until June 2022. Upon identifying the issue, Center for Conflict Resolution was informed, and they reissued a revised May reimbursement request, excluding the held check, and included the expenditure in the July 2022 reimbursement request. The Chicago Bar Foundation is 3 months behind on reimbursements to Center for Conflict Resolution and as such the amount has not been reimbursed as of the date of the audit. Context The lack of internal controls was an isolated issue within the audit period and only affected one expenditure in the last month of the audit period. Criteria `The auditee shall: . . . (b) Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Center for Conflict Resolution?s management had not developed or implemented an effective system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect The failure to establish an effective internal control system placed Center for Conflict Resolution at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of internal controls pertaining to the expenditures and reimbursement requests could have 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. Recommendation We recommended that the Center for Conflict Resolution's management establish controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. 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: Coronavirus Relief Funds ? internal controls Federal Agency: Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds, Coronavirus Relief Fund ALN: 21.019, 21.027 Federal Award numbers and Years (or other identifying numbers): 2020-2021, 2021-2022 Pass-Through Entity: Chicago Bar Foundation Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit finding: Material Weakness Condition An effective internal control system was not in place at the Center for Conflict Resolution in order to ensure compliance with requirements related to the grant agreements and the compliance requirements listed above. Technology expense requested for reimbursement was not actually expended prior to requesting reimbursement in May 2022 in the amount of $95,000. Center for Conflict Resolution recorded the expenditure in May 2022 but did not actually release the check until July 2022 and did not sign the contract until June 2022. Upon identifying the issue, Center for Conflict Resolution was informed, and they reissued a revised May reimbursement request, excluding the held check, and included the expenditure in the July 2022 reimbursement request. The Chicago Bar Foundation is 3 months behind on reimbursements to Center for Conflict Resolution and as such the amount has not been reimbursed as of the date of the audit. Context The lack of internal controls was an isolated issue within the audit period and only affected one expenditure in the last month of the audit period. Criteria `The auditee shall: . . . (b) Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Center for Conflict Resolution?s management had not developed or implemented an effective system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect The failure to establish an effective internal control system placed Center for Conflict Resolution at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of internal controls pertaining to the expenditures and reimbursement requests could have 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. Recommendation We recommended that the Center for Conflict Resolution's management establish controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Institutions are required to be both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of Higher Education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition While without funding for the period, for the calendar quarters ended September 30, 2021 and March 31, 2022, a quarterly report for the Student Aid Portion was not posted. For the calendar quarter ended June 30, 2021, the quarterly report for the Student Aid Portion and Institutional Portion was not submitted within the required 10 days of the quarter end. For the calendar quarter ended September 30, 2021, the quarterly report for the Institutional Portion was not submitted within the required 10 days of the quarter end. Rather the reports were submitted within 15 and 12 days, respectively, of the quarter end. For the calendar quarters ended June 30, 2021 and December 31, 2021, the information reported on the Student Aid Portion quarterly reports for three of the four key line items, was not accurate. The three key line items included total amount distributed to students, number of students that were eligible, and number of students that received a distribution. For the quarter ended June 30, 2021, the total amount distributed to students was inaccurate by $118,403 and the number of students that were eligible and number of students that received a distribution were inaccurate by 13 students. For the quarter ended December 31, 2021, the total amount distributed to students was inaccurate by $21,134 and the number of students that were eligible and number of students that received a distribution were inaccurate by 167 students. Cause and Effect Management?s review control over its reporting requirements for HEERF was not operating at a level of precision to ensure timely and accurate reporting. Therefore, certain required reporting was not posted publicly or submitted, was not submitted timely, or was not accurate. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Institutions are required to be both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of Higher Education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition While without funding for the period, for the calendar quarters ended September 30, 2021 and March 31, 2022, a quarterly report for the Student Aid Portion was not posted. For the calendar quarter ended June 30, 2021, the quarterly report for the Student Aid Portion and Institutional Portion was not submitted within the required 10 days of the quarter end. For the calendar quarter ended September 30, 2021, the quarterly report for the Institutional Portion was not submitted within the required 10 days of the quarter end. Rather the reports were submitted within 15 and 12 days, respectively, of the quarter end. For the calendar quarters ended June 30, 2021 and December 31, 2021, the information reported on the Student Aid Portion quarterly reports for three of the four key line items, was not accurate. The three key line items included total amount distributed to students, number of students that were eligible, and number of students that received a distribution. For the quarter ended June 30, 2021, the total amount distributed to students was inaccurate by $118,403 and the number of students that were eligible and number of students that received a distribution were inaccurate by 13 students. For the quarter ended December 31, 2021, the total amount distributed to students was inaccurate by $21,134 and the number of students that were eligible and number of students that received a distribution were inaccurate by 167 students. Cause and Effect Management?s review control over its reporting requirements for HEERF was not operating at a level of precision to ensure timely and accurate reporting. Therefore, certain required reporting was not posted publicly or submitted, was not submitted timely, or was not accurate. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-005: Reporting Federal Agency U.S. Department of Health and Human Services Federal Programs COVID-19 ? Provider Relief Fund (CFDA 93.498) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Criteria The Provider Relief Fund (PRF) reporting portal should be accurate, including the line item Total Other Provider Relief Fund Expenses. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The University submitted their PRF period one portal reporting on September 30, 2021 which reflected $114,692,613 of Lost Revenues and $14,854,235 of Other Provider Relief Fund Expenses. An amended PRF period one portal reporting was submitted on June 27, 2022 which reflected lost revenues of $114,692,613 and $0 of Other Provider Relief Fund Expenses. The amended period one portal reporting was filed after the due date. Cause and Effect Management?s review control over its reporting requirements for PRF was not operating at a level of precision to initially ensure its accuracy. When management identified an amended report was required, the update to the portal reporting was not made timely. Management did identify and correct the reporting. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over the reporting requirements with an emphasis on making timely updates, as necessary. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-001: Enrollment Reporting Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P063P211285 Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student?s interest subsidy and initiation of repayment periods. Per the NSLDS Enrollment Guide section 4.4.2, the NSLDS has defined the effective date, for both program level and campus level reporting, to be significant data elements. The NSLDS Enrollment Guide states that the effective date for a withdrawal status should be the final day of the term in which the student was last enrolled. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 1 out of 40 students, the student had graduated but the status change was not reported at the campus level or at the program level. For 1 out of 40 students, the student had graduated but the status change was not reported at the program level. For 14 out of 40 students, the effective date of the students? withdrawal status per the program level reporting did not agree to student withdrawal status? effective date per campus level reporting. The campus level effective date was the last day of the Fall semester and the program level effective date was the first day of Spring semester. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the program level and campus level enrollment reporting submissions. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.
Finding 2022-001: Enrollment Reporting Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P063P211285 Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student?s interest subsidy and initiation of repayment periods. Per the NSLDS Enrollment Guide section 4.4.2, the NSLDS has defined the effective date, for both program level and campus level reporting, to be significant data elements. The NSLDS Enrollment Guide states that the effective date for a withdrawal status should be the final day of the term in which the student was last enrolled. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 1 out of 40 students, the student had graduated but the status change was not reported at the campus level or at the program level. For 1 out of 40 students, the student had graduated but the status change was not reported at the program level. For 14 out of 40 students, the effective date of the students? withdrawal status per the program level reporting did not agree to student withdrawal status? effective date per campus level reporting. The campus level effective date was the last day of the Fall semester and the program level effective date was the first day of Spring semester. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the program level and campus level enrollment reporting submissions. Views of Responsible Officials: See management?s corrective action plan.