Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
2024 – 001: Improper Payroll Calculation Federal Agency: U.S. Department of Energy Federal Program Name: Research & Development Cluster Assistance Listing Number: 81.049 Federal Award Identification Number: DE-SC0023385 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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. 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). Compliance – Per 2 CFR § 200.403, except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award to be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award regarding types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. (g) Be adequately documented. Condition: The University incorrectly calculated payroll costs charged to the grant after an employee was double paid for the same work hours. Questioned costs: $400. Context: This condition occurred for 1 out of 40 payroll costs selected for testing resulting in $400 being incorrectly charged to the program. Cause: An employee failed to accurately enter time worked into the university timekeeping system for the pay period 5/1/24 – 5/15/24. The employee reported the hours to their department contact on 5/29/24, which was after the pay period had closed and paychecks had already been processed. The department liaison contacted Kronos Support to have the hours added to the timecard retroactively. Kronos Support received confirmation from the employee that the missed hours could be added to the paycheck for 6/14/24. During payroll processing for 6/14/24, Kronos Support added the missed hours to the employee’s payline on 6/5/24. The department liaison also submitted a CU Special Pay for the same missed hours on 6/5/24. Due to the timing of each separate transaction, Kronos Support did not have visibility into the duplication of the hours. The department failed to identify the duplication during its review of payroll reports. Effect: Expenditures may be incorrectly charged to the program. Repeat Finding: No Recommendation: We recommend that the institution strengthen its internal controls to ensure that expenditures are reviewed and adjusted for, if necessary, in a timely manner. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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. 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). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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. 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). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
Criteria or Specific Requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned Costs: None. Context: During our testing we noted one of forty students, from a statistically valid sample, were disbursed awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to the lack of a manual adjustment that was needed for this instance. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest expected family contributions who will not receive Federal Pell Grants.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University awarded FSEOG to students with EFC’s higher than zero (the lowest expected family contribution) when there were students with the zero EFCs who did not receive FSEOG and were eligible to receive FSEOG. Questioned costs: $800. Context: In our sample of 13 FSEOG recipients two were identified that had an EFC higher than zero. Both were within the University's policy to award eligible students with EFCs in the 0-3500 range who meet the priority deadline. In our eligibility sample of 40, we identified 2 Pell recipients with a zero EFC and remaining need that were not awarded FSEOG funds. Cause: The University's policy is to award FSEOG to PELL recipients who have met the FAFSA priority deadline and have an EFC below 3,500. The University policy for awarding FSEOG funds was not capturing all students who had the lowest EFC and remaining need. Effect: The University is not in compliance with the FSEOG awarding guidelines. Repeat finding: Yes, 2023-004. Recommendation: We recommend that the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; Federal Award Identification Number and Year: P268K240101 – 2024; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) 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 or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of loan disbursements, we identified instances in which students did not receive notification of their loan disbursement. Questioned costs: None. Context: In our testing of loan disbursements, we identified 23 out of 40 students tested did not receive notification of their loan disbursement. Students were only notified if there was a change to their loan award and were not notified of loan disbursements. Cause: The University did not have proper procedures in place to ensure all students were notified of their loan disbursements. Effect: The University was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. Repeat finding: No. Recommendation: We recommend the University evaluate the procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Agriculture; Federal Program Name: Partnerships for Climate-Smart Commodities; Assistance Listing Number: 10.937; Federal Award Identification Number and Year: 2023-2024 – NR233A750004G038; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance. Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have observable controls to test over the Federal Funding. Accountability and Transparency Act (FFATA) reporting process. Questioned costs: None. Context: During our testing of the 3 FFATA reports submitted by the University during the year ended June 30, 2024, we noted there was no documentation of the University’s review process of the FFATA reports. Cause: The procedures the University had over the review of the FFATA reports did not include documentation of the control over reporting. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat finding: No. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Views of responsible officials and planned corrective action: Management agrees they were not able to provide evidence of the review of the FFATA report.
2024 – 001: Special Tests and Provisions – NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231544, P268K241544 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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. 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). Compliance – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported in NSLDS. Questioned costs: None Context: The enrollment data was incorrectly reported for 1 out of 60 students. Cause: The student’s enrollment status update was delayed due to the sequence of file submissions by the college. Although the college transmitted accurate information with each Spring 2024 enrollment file, the initial sequencing of the Fall 2023 graduation file led to a delay in updating the student’s enrollment status and effective date in NSLDS until Fall 2024. Effect: Student enrollment status was not reported accurately in NSLDS. Repeat Finding: No Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Special Tests and Provisions – NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231544, P268K241544 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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. 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). Compliance – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported in NSLDS. Questioned costs: None Context: The enrollment data was incorrectly reported for 1 out of 60 students. Cause: The student’s enrollment status update was delayed due to the sequence of file submissions by the college. Although the college transmitted accurate information with each Spring 2024 enrollment file, the initial sequencing of the Fall 2023 graduation file led to a delay in updating the student’s enrollment status and effective date in NSLDS until Fall 2024. Effect: Student enrollment status was not reported accurately in NSLDS. Repeat Finding: No Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Type of Finding – Significant Deficiency in Internal Control Over Compliance. Condition/Context – Internal control procedures over eligible disbursements did not ensure compliance with federal awards. An employee reimbursement was billed twice, and employee bonuses, which are not allowable costs, were included within the reimbursement request. Criteria – In accordance with the Compliance Supplement Part 6 - Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause – Clerical oversight. Effect – Noncompliance with the Compliance Supplement and Uniform Guidance. Repeat Finding – No Questioned Costs - $12,177 Recommendation – We would recommend management to review and to ensure that expenditures being requested for reimbursement are for allowable costs. View of Responsible Officials – There is no disagreement with the audit findings.
Department of Health and Human Services Federal Financial Assistance Listing #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Reporting Significant Deficiency in Internal Control over Compliance Criteria - 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – There was no evidence retained that the Medical Center’s compliance and financial reports submitted to the Department of Health and Human Services were reviewed and approved prior to submission. Cause - The Medical Center did have an internal control policy in place to ensure documented review and approval of the compliance and financial reports was documented; however, this was not followed consistently throughout the year. Effect - The lack of adequate policies governing review and approval increases the risk that employees participating in the federal awards administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs - None Reported. Context/Sampling - A nonstatistical sample of 10 out of 69 reports were selected for detail testing and 5 did not include evidence of a review by someone other than the preparer. Repeat Finding from Prior Year(s) – Yes, 2022-002 Recommendation - We recommend the Medical Center follow its internal control policies to ensure that formal documentation of review and approval is obtained and retained. Views of Responsible Officials – Management agrees with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P230097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their EFC and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. All Schedules, however, are based on the COA of a full-time student for a full academic year (see Volume 7, The Federal Pell Grant Program and Iraq and Afghanistan Service Grants, of the FSA Handbook for 2023-24 for guidance on selecting formulas for calculating cost of attendance, prorating costs for programs less or greater than an academic year and determining payment periods). Disbursement schedules for 20222023 and 2023-2024 award years can be found at the following links: 2022-2023 Federal Pell Grant Payment and Disbursement Schedules (GEN-22-04) and 2023-2024 Federal Pell Grant Payment and Disbursement Schedules (GEN-23-02). Students that receive Pell Grant may not receive more than six Scheduled Awards (12 semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU) field in COD (tracked by ED) (20 USC 1070a(c)(5)). The LEU maximum percentage for student eligibility is 600 percent. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing our testing of return of Title IV funds, one student had been awarded Pell when they were not eligible to receive Pell due to the timing of the award. Context: During our Return of Title IV testing, we selected forty samples to test. While testing eligibility was not the focus of this test, the University brought to our attention one exception of a student being awarded Pell when they were not eligible to receive Pell due to the timing of the award. We also tested 40 other students in our eligibility testing in which no exceptions were identified. Questioned costs: $1,879. Effect: The University was out of compliance with the requirement to properly award students Title IV funds based on eligibility. Additionally, the University was out of compliance as it relates to properly calculating the return of Title IV funds. Cause: Per discussion with the University, Pell was awarded erroneously and a review process did not identify the issue prior to disbursing the aid. Repeat finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds to ensure only eligible students are receiving funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal 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. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal 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. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 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 awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. 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: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 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 awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. 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: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 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 awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. 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: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 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 awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. 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: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 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 awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Views of responsible officials: There is no disagreement with the audit finding.