Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 668.34(d)(1) requires that an institution that evaluates satisfactory academic progress annually or less frequently than at the end of each payment period and determines that a student is not making progress under its policy may nevertheless disburse Title IV, HEA program funds to the student under the provisions of 34 CFR 668.34(d)(2) or 34 CFR 668.34(d)(3). Condition: As stated in the Financial Aid SAP policy, to successfully make and maintain SAP, a student must maintain a cumulative grade point average of 2.0 or higher for undergraduate students. A student who does not meet the minimum requirements for the rate of completion or cumulative GPA will be sent an SAP Warning and will have one semester to meet SAP requirements. If the student does not meet the required minimum GPA or credit hour completion rate at the end of the warning term, their financial aid will be suspended. During our testing of students’ eligibility for financial aid, 1 out of 40 students who received financial aid did not meet the satisfactory academic progress requirements as stated in the SAP policy. Additionally, 1 out of 40 students who did not meet the SAP cumulative GPA requirement was marked incorrectly as “Satisfactory SAP” instead of “Warning”. Questioned costs: $12,847 Context: This condition occurred in 2 out of 40 students tested. Cause: Students’ GPA was not reviewed closely enough to determine if students meet the requirements to received financial aid. Effect: Students who did not meet the SAP requirements and ineligible to receive financial aid were granted aid. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures around the review and determination of students’ eligibility to receive financial aid. Views of responsible officials: There is no disagreement with the audit finding.
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 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally-related expenses assessed by the institution. Condition: Incorrect institutional charges were utilized as inputs in the calculation of R2T4 for these students. Questioned costs: None Context: This condition occurred in 2 out of 5 students tested. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct institutional charges and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 668.34(d)(1) requires that an institution that evaluates satisfactory academic progress annually or less frequently than at the end of each payment period and determines that a student is not making progress under its policy may nevertheless disburse Title IV, HEA program funds to the student under the provisions of 34 CFR 668.34(d)(2) or 34 CFR 668.34(d)(3). Condition: As stated in the Financial Aid SAP policy, to successfully make and maintain SAP, a student must maintain a cumulative grade point average of 2.0 or higher for undergraduate students. A student who does not meet the minimum requirements for the rate of completion or cumulative GPA will be sent an SAP Warning and will have one semester to meet SAP requirements. If the student does not meet the required minimum GPA or credit hour completion rate at the end of the warning term, their financial aid will be suspended. During our testing of students’ eligibility for financial aid, 1 out of 40 students who received financial aid did not meet the satisfactory academic progress requirements as stated in the SAP policy. Additionally, 1 out of 40 students who did not meet the SAP cumulative GPA requirement was marked incorrectly as “Satisfactory SAP” instead of “Warning”. Questioned costs: $12,847 Context: This condition occurred in 2 out of 40 students tested. Cause: Students’ GPA was not reviewed closely enough to determine if students meet the requirements to received financial aid. Effect: Students who did not meet the SAP requirements and ineligible to receive financial aid were granted aid. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures around the review and determination of students’ eligibility to receive financial aid. Views of responsible officials: There is no disagreement with the audit finding.
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 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally-related expenses assessed by the institution. Condition: Incorrect institutional charges were utilized as inputs in the calculation of R2T4 for these students. Questioned costs: None Context: This condition occurred in 2 out of 5 students tested. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct institutional charges and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 668.34(d)(1) requires that an institution that evaluates satisfactory academic progress annually or less frequently than at the end of each payment period and determines that a student is not making progress under its policy may nevertheless disburse Title IV, HEA program funds to the student under the provisions of 34 CFR 668.34(d)(2) or 34 CFR 668.34(d)(3). Condition: As stated in the Financial Aid SAP policy, to successfully make and maintain SAP, a student must maintain a cumulative grade point average of 2.0 or higher for undergraduate students. A student who does not meet the minimum requirements for the rate of completion or cumulative GPA will be sent an SAP Warning and will have one semester to meet SAP requirements. If the student does not meet the required minimum GPA or credit hour completion rate at the end of the warning term, their financial aid will be suspended. During our testing of students’ eligibility for financial aid, 1 out of 40 students who received financial aid did not meet the satisfactory academic progress requirements as stated in the SAP policy. Additionally, 1 out of 40 students who did not meet the SAP cumulative GPA requirement was marked incorrectly as “Satisfactory SAP” instead of “Warning”. Questioned costs: $12,847 Context: This condition occurred in 2 out of 40 students tested. Cause: Students’ GPA was not reviewed closely enough to determine if students meet the requirements to received financial aid. Effect: Students who did not meet the SAP requirements and ineligible to receive financial aid were granted aid. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures around the review and determination of students’ eligibility to receive financial aid. Views of responsible officials: There is no disagreement with the audit finding.
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 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally-related expenses assessed by the institution. Condition: Incorrect institutional charges were utilized as inputs in the calculation of R2T4 for these students. Questioned costs: None Context: This condition occurred in 2 out of 5 students tested. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct institutional charges and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 668.34(d)(1) requires that an institution that evaluates satisfactory academic progress annually or less frequently than at the end of each payment period and determines that a student is not making progress under its policy may nevertheless disburse Title IV, HEA program funds to the student under the provisions of 34 CFR 668.34(d)(2) or 34 CFR 668.34(d)(3). Condition: As stated in the Financial Aid SAP policy, to successfully make and maintain SAP, a student must maintain a cumulative grade point average of 2.0 or higher for undergraduate students. A student who does not meet the minimum requirements for the rate of completion or cumulative GPA will be sent an SAP Warning and will have one semester to meet SAP requirements. If the student does not meet the required minimum GPA or credit hour completion rate at the end of the warning term, their financial aid will be suspended. During our testing of students’ eligibility for financial aid, 1 out of 40 students who received financial aid did not meet the satisfactory academic progress requirements as stated in the SAP policy. Additionally, 1 out of 40 students who did not meet the SAP cumulative GPA requirement was marked incorrectly as “Satisfactory SAP” instead of “Warning”. Questioned costs: $12,847 Context: This condition occurred in 2 out of 40 students tested. Cause: Students’ GPA was not reviewed closely enough to determine if students meet the requirements to received financial aid. Effect: Students who did not meet the SAP requirements and ineligible to receive financial aid were granted aid. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures around the review and determination of students’ eligibility to receive financial aid. Views of responsible officials: There is no disagreement with the audit finding.
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 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally-related expenses assessed by the institution. Condition: Incorrect institutional charges were utilized as inputs in the calculation of R2T4 for these students. Questioned costs: None Context: This condition occurred in 2 out of 5 students tested. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct institutional charges and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 674.16 states that before an institution makes its first disbursement to a student, the student shall sign the promissory note and the institution shall provide the student with certain repayment information. Condition: There is no Perkins loam promissory note on file for certain students with open and retired loans. These promissory notes could not be located. Questioned costs: $12,159 Context: This condition occurred in 5 out of 40 students tested with open loans and for 3 out of 8 students tested with retired loans. Cause: The University was not able to locate these promissory notes. Effect: The University cannot provide documentation showing proper completion of promissory note as required by DOE requirements. Repeat Finding: No Recommendation: We recommend that the University implement a procedure be put in place to ensure proper record retention documenting the completion of promissory notes. Views of responsible officials: There is no disagreement with the audit finding.
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). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: For students participating in the Federal Direct Loan and Pell Grant programs, the enrollment status change to withdrawal was not timely reported to NSLDS. Questioned costs: None Context: This condition occurred in 1 out of 17 students tested. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
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 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: For students participating in the Federal Direct Loan and Pell Grant programs, the enrollment status change to withdrawal was not timely reported to NSLDS. Questioned costs: None Context: This condition occurred in 1 out of 17 students tested. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2024-003 – Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (NSLDS) through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Certain students’ enrollment information was not reported accurately and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: 1 student out of a sample of 60 students tested was reported with the incorrect enrollment status and effective date at both the campus and program levels. 1 student out of a sample of 60 students tested did not have a required published length identified in the program NSLDS screen. 1 student out of a sample of 60 students tested has no record found in NSLDS. However, the student received aid and should have been reported to NSLDS. 2 students out of a sample of 60 students reported were reported with the incorrect enrollment status effective date at the campus level. 7 students out of a sample of 60 students tested were reported as a withdrawal status at both the campus and program levels but was graduated per Institution’s record, and student status was never subsequently updated. 59 students out of a sample of 60 students tested, were reported outside the 30 or 60 day window. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. The Department responsible for NSLDS reporting at the University experienced turnover at a senior level. Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, 2023-005. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-004 – Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Student refund checks related to Title IV funds were not returned to the ED within the required timeframe. Questioned Costs: N/A Context: During the testing of student refund check reconciliations, it was noted that 8 student refund checks were not returned to the ED within the 240-day timeframe. Additionally, an outstanding check listing was only able to be provided as of December 16, 2024. Cause: The University’s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University is not returning funds in accordance with ED guidelines. Population of outstanding checks could not be provided as of June 30, 2024. Repeat Finding: Yes, 2023-006. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-006 – Gramm-Leach-Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The information security program should provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University’s should document the periodic user access reviews as part of the formalized access management policies and procedures. Questioned Costs: N/A Context: The University was not documenting the periodic user access review performed over the audit period. Cause: University does not have the policies and procedures in place to ensure the written information security program is in compliance with GLBA. Effect: Management is not documenting their periodic review of user access. Repeat Finding: Yes, 2023-009. Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-003 – Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (NSLDS) through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Certain students’ enrollment information was not reported accurately and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: 1 student out of a sample of 60 students tested was reported with the incorrect enrollment status and effective date at both the campus and program levels. 1 student out of a sample of 60 students tested did not have a required published length identified in the program NSLDS screen. 1 student out of a sample of 60 students tested has no record found in NSLDS. However, the student received aid and should have been reported to NSLDS. 2 students out of a sample of 60 students reported were reported with the incorrect enrollment status effective date at the campus level. 7 students out of a sample of 60 students tested were reported as a withdrawal status at both the campus and program levels but was graduated per Institution’s record, and student status was never subsequently updated. 59 students out of a sample of 60 students tested, were reported outside the 30 or 60 day window. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. The Department responsible for NSLDS reporting at the University experienced turnover at a senior level. Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, 2023-005. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-004 – Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Student refund checks related to Title IV funds were not returned to the ED within the required timeframe. Questioned Costs: N/A Context: During the testing of student refund check reconciliations, it was noted that 8 student refund checks were not returned to the ED within the 240-day timeframe. Additionally, an outstanding check listing was only able to be provided as of December 16, 2024. Cause: The University’s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University is not returning funds in accordance with ED guidelines. Population of outstanding checks could not be provided as of June 30, 2024. Repeat Finding: Yes, 2023-006. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-004 – Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Student refund checks related to Title IV funds were not returned to the ED within the required timeframe. Questioned Costs: N/A Context: During the testing of student refund check reconciliations, it was noted that 8 student refund checks were not returned to the ED within the 240-day timeframe. Additionally, an outstanding check listing was only able to be provided as of December 16, 2024. Cause: The University’s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University is not returning funds in accordance with ED guidelines. Population of outstanding checks could not be provided as of June 30, 2024. Repeat Finding: Yes, 2023-006. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-006 – Gramm-Leach-Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The information security program should provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University’s should document the periodic user access reviews as part of the formalized access management policies and procedures. Questioned Costs: N/A Context: The University was not documenting the periodic user access review performed over the audit period. Cause: University does not have the policies and procedures in place to ensure the written information security program is in compliance with GLBA. Effect: Management is not documenting their periodic review of user access. Repeat Finding: Yes, 2023-009. Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-006 – Gramm-Leach-Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The information security program should provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University’s should document the periodic user access reviews as part of the formalized access management policies and procedures. Questioned Costs: N/A Context: The University was not documenting the periodic user access review performed over the audit period. Cause: University does not have the policies and procedures in place to ensure the written information security program is in compliance with GLBA. Effect: Management is not documenting their periodic review of user access. Repeat Finding: Yes, 2023-009. Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-006 – Gramm-Leach-Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all grants were awarded within 2022-2023 and 2023-2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The information security program should provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University’s should document the periodic user access reviews as part of the formalized access management policies and procedures. Questioned Costs: N/A Context: The University was not documenting the periodic user access review performed over the audit period. Cause: University does not have the policies and procedures in place to ensure the written information security program is in compliance with GLBA. Effect: Management is not documenting their periodic review of user access. Repeat Finding: Yes, 2023-009. Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Finding Number: 2024-001 Repeat Finding: No Program Name/Assistance Listing Title: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Federal Agency: Arizona Department of Transportation Federal Award Number: GRT-22-0008862-T Pass-Through Agency: Arizona Department of Transportation Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Other Criteria Management is responsible for establishing and maintaining internal controls over its accounting records. Further, in accordance with 2 CFR 200.510, the entity is responsible for the design and implementation of controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) each fiscal year. Additionally, 2 CFR 200.303 requires the entity to establish and maintain internal control over the federal awards that provides reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition YCIPTA was awarded a match for the purchase of a new bus. YCIPTA did not follow federal regulations regarding federal revenue transactions to ensure all activities were properly recorded and processed. Cause YCIPTA has not implemented sufficient controls over accounting transactions. Effect YCIPTA was not in compliance with federal regulations and guidelines. The transaction was unique and not part of the normal federal program operations. It was not known that the transaction was subject to Single Audit. Audit adjustments were required to properly reflect the activity. Context YCIPTA received a federal match for the purchase of a new bus. The following errors were noted in the recording of the bus: A bus valued at $120,488 was not recorded in the general ledger. The corresponding depreciation expense (and accumulated depreciation) of $20,081 was not recorded in the general ledger. Capital outlay of $12,753 was recorded in error in the general ledger Federal revenue of $107,735 for the match was not recorded in the general ledger or on the SEFA for the fiscal year. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should improve internal controls and adhere to federal regulations. All applicable transactions and activity should be included in the SEFA for the fiscal year in which the expenditures occurred. Views of Responsible Officials See Corrective Action Plan.
Prior Year Finding: 2023-004 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: 2018,2019,2020,2023 Pass-Through Entity: N/A Award Number and Period: B-18-MC-51-0018 (7/1/18-9/1/26) B-19-MC-51-0018 (7/1/19-9/1/27) B-20-MC-51-0018 (7/1/20-9/1/28) B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance - Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 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 comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not report subaward information to FSRS during FY 2024. Context: None of the ten subawards selected for testing were reported to FSRS during FY 2024. Total subawards selected were $50,000.00, and $-0- was reported as required by FFATA requirements. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $50,000.00 $50,000.00 $0 $0 $0 Cause: The City's procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2024. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the City establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: 2023-004 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: 2018,2019,2020,2023 Pass-Through Entity: N/A Award Number and Period: B-18-MC-51-0018 (7/1/18-9/1/26) B-19-MC-51-0018 (7/1/19-9/1/27) B-20-MC-51-0018 (7/1/20-9/1/28) B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance - Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 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 comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not report subaward information to FSRS during FY 2024. Context: None of the ten subawards selected for testing were reported to FSRS during FY 2024. Total subawards selected were $50,000.00, and $-0- was reported as required by FFATA requirements. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $50,000.00 $50,000.00 $0 $0 $0 Cause: The City's procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2024. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the City establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: 2023-004 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: 2018,2019,2020,2023 Pass-Through Entity: N/A Award Number and Period: B-18-MC-51-0018 (7/1/18-9/1/26) B-19-MC-51-0018 (7/1/19-9/1/27) B-20-MC-51-0018 (7/1/20-9/1/28) B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance - Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 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 comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not report subaward information to FSRS during FY 2024. Context: None of the ten subawards selected for testing were reported to FSRS during FY 2024. Total subawards selected were $50,000.00, and $-0- was reported as required by FFATA requirements. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $50,000.00 $50,000.00 $0 $0 $0 Cause: The City's procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2024. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the City establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: 2023-004 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: 2018,2019,2020,2023 Pass-Through Entity: N/A Award Number and Period: B-18-MC-51-0018 (7/1/18-9/1/26) B-19-MC-51-0018 (7/1/19-9/1/27) B-20-MC-51-0018 (7/1/20-9/1/28) B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance - Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 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 comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not report subaward information to FSRS during FY 2024. Context: None of the ten subawards selected for testing were reported to FSRS during FY 2024. Total subawards selected were $50,000.00, and $-0- was reported as required by FFATA requirements. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $50,000.00 $50,000.00 $0 $0 $0 Cause: The City's procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2024. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the City establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: 2023-004 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: 2018,2019,2020,2023 Pass-Through Entity: N/A Award Number and Period: B-18-MC-51-0018 (7/1/18-9/1/26) B-19-MC-51-0018 (7/1/19-9/1/27) B-20-MC-51-0018 (7/1/20-9/1/28) B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance - Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 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 comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not report subaward information to FSRS during FY 2024. Context: None of the ten subawards selected for testing were reported to FSRS during FY 2024. Total subawards selected were $50,000.00, and $-0- was reported as required by FFATA requirements. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $50,000.00 $50,000.00 $0 $0 $0 Cause: The City's procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2024. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the City establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding:Significant Deficiency in Internal Control Over Compliance 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 nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not have adequate internal controls in place to manage and monitor the distribution and usage of gift cards. Specifically, there were no formal procedures for tracking the issuance, distribution, and reconciliation of gift cards. This lack of controls resulted in an inability to ensure that gift cards were used for their intended purposes and increased the risk of misappropriation or misuse. Context None, the finding relates to the maintenance of records. Questioned costs: None noted Cause: The City's initial response was to provide immediate financial assistance to the City's residents. As a result, the time to establish adequate internal controls that prevent and/or detect errors and irregularities was decreased. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding:Significant Deficiency in Internal Control Over Compliance 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 nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not have adequate internal controls in place to manage and monitor the distribution and usage of gift cards. Specifically, there were no formal procedures for tracking the issuance, distribution, and reconciliation of gift cards. This lack of controls resulted in an inability to ensure that gift cards were used for their intended purposes and increased the risk of misappropriation or misuse. Context None, the finding relates to the maintenance of records. Questioned costs: None noted Cause: The City's initial response was to provide immediate financial assistance to the City's residents. As a result, the time to establish adequate internal controls that prevent and/or detect errors and irregularities was decreased. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding:Significant Deficiency in Internal Control Over Compliance 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 nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not have adequate internal controls in place to manage and monitor the distribution and usage of gift cards. Specifically, there were no formal procedures for tracking the issuance, distribution, and reconciliation of gift cards. This lack of controls resulted in an inability to ensure that gift cards were used for their intended purposes and increased the risk of misappropriation or misuse. Context None, the finding relates to the maintenance of records. Questioned costs: None noted Cause: The City's initial response was to provide immediate financial assistance to the City's residents. As a result, the time to establish adequate internal controls that prevent and/or detect errors and irregularities was decreased. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding:Significant Deficiency in Internal Control Over Compliance 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 nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Portsmouth did not have adequate internal controls in place to manage and monitor the distribution and usage of gift cards. Specifically, there were no formal procedures for tracking the issuance, distribution, and reconciliation of gift cards. This lack of controls resulted in an inability to ensure that gift cards were used for their intended purposes and increased the risk of misappropriation or misuse. Context None, the finding relates to the maintenance of records. Questioned costs: None noted Cause: The City's initial response was to provide immediate financial assistance to the City's residents. As a result, the time to establish adequate internal controls that prevent and/or detect errors and irregularities was decreased. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance - Recipients may use CSLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 USC 802 and 42 USC 803 respectively). 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). Condition: The City developed policies to determine the allowable uses of gift cards under the program+ including supporting documentation to be obtained prior to distribution of the gift cards. The City was not in compliance with its internal policy for obtaining required supporting documentation. Context: CLA noted that 2 out of 60 samples did not have support for the current year school contract and 2 out of 60 samples did not have support for proof of school or VA State ID. Questioned costs: $2,100 Cause: The City initially responded by offering immediate financial assistance to its residents. Consequently, this led to the bypassing of internal controls related to supporting documentation. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to internal controls. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance - Recipients may use CSLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 USC 802 and 42 USC 803 respectively). 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). Condition: The City developed policies to determine the allowable uses of gift cards under the program+ including supporting documentation to be obtained prior to distribution of the gift cards. The City was not in compliance with its internal policy for obtaining required supporting documentation. Context: CLA noted that 2 out of 60 samples did not have support for the current year school contract and 2 out of 60 samples did not have support for proof of school or VA State ID. Questioned costs: $2,100 Cause: The City initially responded by offering immediate financial assistance to its residents. Consequently, this led to the bypassing of internal controls related to supporting documentation. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to internal controls. Views of responsible officials: Management agrees with the finding.