Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-002 – N. Special Tests and Provisions – Federal Perkins Loan Program Recordkeeping and Record Retention Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.038) Criteria or Specific Requirement – Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using a master promissory note for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third party servicer’s most recent Title IV compliance audit. When an institution uses a third-party servicer for its Federal Perkins Loan Program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Certain Federal Perkins Loan Program records selected for testing were missing a signed master promissory note, missing repayment schedules, missing documentation for the first disbursement, missing documentation for the last payment, or missing other documentation. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with the Federal Perkins Loan Program recordkeeping and record retention requirements. Questioned Costs – None. Context – For 1 of 40 Federal Perkins Loan Program records selected for testing, we noted that 1 record was missing a signed master promissory note and a repayment schedule. Indication of Repeat Finding - This is a repeat of prior year finding 2023-005. Recommendation – We recommend that the University enhance its procedures and internal controls related to Federal Perkins Loan Program recordkeeping and record retention. Views of Responsible Officials – The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education. Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program: 1. Notified the Department of Education of the intent to liquidate. 2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process. 3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD) 4. Remitted the federal share to the Department 5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD) The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-004 – E. Eligibility – Over award of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268) Criteria or Specific Requirement – Student financial assistance awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A student was awarded total aid in excess of the student’s cost of attendance. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A student received total aid in excess of the student’s cost of attendance resulting in the University not being in compliance with eligibility requirements. Questioned Costs – Known questioned costs were $2,742 which were specific to 1 of 25 student selected for eligibility testing who received total aid in excess of the student’s cost of attendance. Context – For 1 of 25 students selected for eligibility testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to award of student financial assistance awards to prevent total aid from being award in excess of the student’s cost of attendance. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly. 2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs. By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements.
Finding 2024-005 – L. Reporting – Financial Reporting Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268) Criteria or Specific Requirement – Institutions submit Federal Direct Student Loans, Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education Grants, and Iraq and Afghanistan Service Grant origination records and disbursement records to the Common Origination and Disbursement (“COD”) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. U.S. Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data U.S. Department of Education has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – For a disbursement of Federal Direct Student Loans program funds, the University did not submit the origination and disbursement records to the COD system within the required timeframes. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University did not submit the origination and disbursement records to the COD system within the required timeframes resulting in the University not being in compliance with the financial reporting requirements. Questioned Costs – None. Context – For 1 of 25 students selected for COD reporting testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the submission of origination and disbursement records to the COD system. Views of Responsible Officials – The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Suspension and debarment Questioned costs: None Condition—Contrary to federal regulations, the County did not maintain documentation that it had verified 5 of 9 vendors we tested were not suspended or debarred from doing business with the federal government prior to making the purchases. The vendors were paid program monies totaling $740,467, or 49 percent of the program’s total federal award expenditures of $1.5 million. Effect—As the County could not demonstrate that at the time of the purchases it obtained services from vendors that had not been suspended or debarred from doing business with the federal government, the County was at increased risk that it could have paid federal program monies to unallowable vendors. Subsequently, we performed additional audit procedures and verified the vendors had not been suspended or debarred by the federal government. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The County had informal procedures that were not consistently applied and lacked policies and procedures to verify that vendors, including those procured by the State of Arizona or through cooperative agreements, were not suspended or debarred from doing business with the federal government each year and to maintain documentation of this verification within the procurement files. Criteria—Federal regulations require the County to verify that vendors being paid more than $25,000 in federal program monies have not been suspended or debarred by either checking their suspension and debarment status, obtaining the vendor’s certification stating they are not suspended or debarred, and/or adding a condition regarding suspension and debarment to the purchase contract with the vendor (2 CFR §180.300). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The County should: 1. Verify and maintain documentation that a vendor being paid more than $25,000 in federal program monies has not been suspended or debarred from doing business with the federal government. 2. Develop policies and procedures and train staff to: a. Verify the vendor’s suspension and debarment status prior to making purchases by examining the federal government’s sam.gov website, obtaining certification from the vendor, or adding a condition in the vendor contract. b. Maintain documentation of this verification within the procurement files.
2024 – 004 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award and Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Under 2 CFR section 200.303, a nonfederal entity must establish and maintain effective internal controls over the federal awards 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). Timely review and approval should be maintained to ensure accurate amounts are being drawn down and accurate reports are submitted. Condition: The Organization did not have adequate internal controls in place for the full fiscal year to ensure cash drawdowns and required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: Two of the three reimbursement requests and five of the five reports selected for testing did not have support retained to show the drawdowns, financial status reports, and other performance reports were reviewed and approved prior to submission. Cause: Management did not have a separate individual assigned to review the cash drawdowns and required reports for the Crime Victim Assistance program after being prepared by the Director of Finance for the full fiscal year. Effect: Potential for inaccurate amounts of funds to be requested or inaccurate information reported. Repeat Finding: This is a repeat finding. Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Views of Responsible Officials and Planned Corrective Actions: The Organization has designated an individual to review and approve the cash drawdowns and reports prior to submission.
2024-002 Allowable Costs, Subrecipient Reimbursement Coronavirus State & Local Fiscal Recovery Funds – Assistance Listing No. 21.027 – COVID-19 Funding Award Number: 24 QAAA 186913 – Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: The Organization did not have records to adequately support costs reimbursed to a subrecipient for the month of August 2023. Criteria: According to 2 CFR 200.302(b)(3), The financial management system of each non-Federal entity must provide for the following: (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Additionally, 2 CFR 200.303(a) states the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned Costs: The total amount reimbursed to the subrecipient for the month of August 2023 of $49,772.27. Cause: The Organization did not obtain source documentation from the sampled subrecipient supporting amounts reimbursed for the month of August 2023. Effect: Costs that are not allowable per the terms and conditions of the grant and/or Uniform Guidance, or improper costs passed through to subrecipients could be charged to the grant. Unallowable or improper costs could be required to be paid back to the Federal awarding agency (and/or pass-through entity). Recommendation: The Organization should strengthen policies and procedures to support a system of internal control regarding review and approval of subrecipient reimbursement requests to ensure costs are backed by source documentation supporting accuracy and allowability prior to payment. Views of Responsible Officials and Planned Corrective Actions: Invest in Kids made multiple requests for source documentation from the subrecipient. However, due to management turnover, the subrecipient lacked personnel with the knowledge to retrieve the requested information. Acknowledging this challenge, Invest in Kids updated its policies and procedures in October 2024. Additionally, all staff participated in the organization's annual financial management and internal controls training that same month. To note, upon completion of this audit, the subrecipient is no longer involved in Invest in Kids programming.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
2024-001 Lack of Documentation to Support Distribution of Wages (Significant Deficiency) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID – 19 Education Stabilization Fund Assistance Listing Numbers: 84.425D/84.425U Passed-through Identification: #20220358 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Significant Deficiency Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll charged to the ESSER III (#20220358) grant it was noted the district gave out retention bonuses to all staff working at Haverhill Cooperative School District. Although a record of bonus recipients was maintained, it was not formally approved by the Superintendent and/or the School Board. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee’s wages paid using grant funds. Questioned Costs: $33,557 Repeat Finding: No Recommendation: We recommend that if the district chooses to maintain a master spreadsheet for stipends or retention bonuses, the list should be formally reviewed and approved by both the School Board and the Superintendent. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Finding 2024-007: Time Accounting (50000) Repeat Finding? This is a partial repeat of Finding 2023-009. Program Identification: Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants: Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) Criteria: 2 CFR, section 200.430 states, in part: (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR, section 200.303 states, in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: Be prepared at least semiannually. Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective. Personnel Activity Report Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach is to provide more documentation rather than less. Condition: Five employees that had complete PARs for time accounting had the following deficiencies: Salaries and benefits were charged 100% to Title I, Part A for these individuals, each month’s salary was not reconciled to reflect the percentage on their PARs. PARs were only provided for 4 months of the fiscal year, the remaining PAR reports requested were not provided. Context: Exceptions were identified for all five employees who were subject to PAR reporting. Questioned Costs: Auditor is estimating that Title I, Part A, was overcharged by $30,205 because the District did not modify each month’s charges to the actual percentage worked on the program. This overcharge was based on averaging the percentage for the four months of PARs we were provided. Cause: District lacks adequate controls to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: Estimated cost questioned of $30,205 for the 2023-24 fiscal year. Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905, which require that employee time certification forms be maintained for employees who charge time to federal program. Views of Responsible Officials: The District acknowledges this finding and is committed to strengthening internal controls to ensure compliance with federal time accounting requirements. The State and Federal Programs Department has received training on Time and Effort procedures, and additional training is being provided to school sites to reinforce accurate time certification and documentation for federal fund expenditures. To address the deficiencies, the District will shift from an annual to a monthly reconciliation process, ensuring that employee salaries charged to Title I accurately reflect actual work performed. The State and Federal Programs Department will collaborate with the Budget Department to systematically track employees funded through Title I and verify that all required PARs are completed and maintained. These corrective actions will enhance oversight, reduce the risk of discrepancies, and improve compliance with federal regulations. The District is committed to ongoing monitoring and training to prevent recurrence and ensure the integrity of financial reporting.
SIGNIFICANT DEFICIENCY 2024-001 – Allowed/Unallowed Activities/Costs Federal Program Information: Department of Education CFDA - 84.010A - Title I Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303 and 2 CFR 200.430 g Condition: During audit procedures, it was identified that the Unit charged unallowable costs to the grant. It was also identified that the unit is incorrectly documenting wages. Cause: The Unit does not have the necessary internal controls over compliance. Effect: The Unit is not ensuring that staff has the appropriate compliance knowledge on allowable and unallowable costs to minimize the inherent risk of unallowable charges to the grant, which could result in return of funding. Of the 5 disbursements reviewed and tested 2 were for unallowable costs that had been charged to the grant. The unit is not consistent with wage documentation which can result in incorrect amounts being paid to personnel. Of the 25 samples reviewed, two staff did not have wage rates documented in the file of which one of them was paid according to the Collective Bargaining Agreement, however the amount paid was incorrect and there is no documentation for the employee who worked just for the summer. Another employee’s contract stated the incorrect salary but was correctly stated in the payroll system. Lastly one hourly employee’s pay was prorated when it shouldn’t have been resulting in an overpayment. Identification of Questioned Costs: None identified. Context: Of a population of 12 AP samples 5 were examined and tested and of a population of 56 payroll samples 25 were examined and tested. This is not a statistically valid sample. Repeat Finding: This is a repeat finding of 2023-002 Recommendation: It is recommended that the Unit implements internal control processes and procedures to ensure that the unit stays in compliance with allowable costs and activities and correct and accurate documentation is being maintained and recorded. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan.
SIGNIFICANT DEFICIENCY 2024-001 – Allowed/Unallowed Activities/Costs Federal Program Information: Department of Education CFDA - 84.010A - Title I Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303 and 2 CFR 200.430 g Condition: During audit procedures, it was identified that the Unit charged unallowable costs to the grant. It was also identified that the unit is incorrectly documenting wages. Cause: The Unit does not have the necessary internal controls over compliance. Effect: The Unit is not ensuring that staff has the appropriate compliance knowledge on allowable and unallowable costs to minimize the inherent risk of unallowable charges to the grant, which could result in return of funding. Of the 5 disbursements reviewed and tested 2 were for unallowable costs that had been charged to the grant. The unit is not consistent with wage documentation which can result in incorrect amounts being paid to personnel. Of the 25 samples reviewed, two staff did not have wage rates documented in the file of which one of them was paid according to the Collective Bargaining Agreement, however the amount paid was incorrect and there is no documentation for the employee who worked just for the summer. Another employee’s contract stated the incorrect salary but was correctly stated in the payroll system. Lastly one hourly employee’s pay was prorated when it shouldn’t have been resulting in an overpayment. Identification of Questioned Costs: None identified. Context: Of a population of 12 AP samples 5 were examined and tested and of a population of 56 payroll samples 25 were examined and tested. This is not a statistically valid sample. Repeat Finding: This is a repeat finding of 2023-002 Recommendation: It is recommended that the Unit implements internal control processes and procedures to ensure that the unit stays in compliance with allowable costs and activities and correct and accurate documentation is being maintained and recorded. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan.
2024-008: U.S. Department of Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all awards under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that charges for salaries and wages must be based on records that accurately reflect the work performed. In part, the records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that, in part, that the system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the federal award is accurate, allowable, and properly allocated. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Labor rates charged to the federal award did not agree to underlying support of payroll costs. In addition, labor rates were not reviewed prior to being charged to the federal award. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to ensure payroll costs charged to the federal award were accurate. Effect: Inaccurate payroll costs were charged to the federal award, which resulted in an underbilling of actual payroll costs. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 ($50,798) out of a population of 433 ($420,962) payroll expenditures at the District was selected for testing. We noted 24 payroll transactions did not agree to underlying support for the employees payroll and fringe rate. These 24 payroll transactions totaled $20,798 and were underbilled to the federal award by $422. In addition, the labor rates charged to the federal award were not reviewed on any of the 60 transactions. Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to ensure payroll costs charged to the federal award are accurate. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-009: U.S. Department of The Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement. Effect: Inaccurate information may be reported and funds may not be drawn on a reimbursement basis. Questioned Costs: None Context/Sampling: A nonstatistical sample of 2 Requests for Reimbursement out of a population of 4 was selected for testing. We noted that there was no evidence of review on one of the Requests for Reimbursement. Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-010: U.S. Department of Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The grant awards require the submission of Federal Financial Reports (SF-425) and Performance Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported did not agree to underlying supporting records. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to provide for the documented review and approval of SF-425 reports or Performance Reports. Effect: Inaccurate information was reported to the federal agency on the SF-425 and inaccurate information was reported to the pass-through entity on the Performance Reports. Questioned Costs: None Context/Sampling: A non-statistical sample of two SF-425 reports out of a population of four was selected for testing. A non-statistical sample of two Performance Reports out of a population of four was selected for testing. We noted that there was no evidence of review on all four reports tested. Amounts reported on all four reports tested did not agree to underlying support. Errors are noted as follows: SF-425 for Quarter Ended 9/30/2023: SF-425 for Quarter Ended 3/31/2024: Performance Report to TRCD for Quarter End 9/30/2023: Performance Report to TRCD for Quarter End 12/31/2023: Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to provide for the documented review and approval of SF-425 reports and Performance Reports. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-008: U.S. Department of Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all awards under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that charges for salaries and wages must be based on records that accurately reflect the work performed. In part, the records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that, in part, that the system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the federal award is accurate, allowable, and properly allocated. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Labor rates charged to the federal award did not agree to underlying support of payroll costs. In addition, labor rates were not reviewed prior to being charged to the federal award. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to ensure payroll costs charged to the federal award were accurate. Effect: Inaccurate payroll costs were charged to the federal award, which resulted in an underbilling of actual payroll costs. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 ($50,798) out of a population of 433 ($420,962) payroll expenditures at the District was selected for testing. We noted 24 payroll transactions did not agree to underlying support for the employees payroll and fringe rate. These 24 payroll transactions totaled $20,798 and were underbilled to the federal award by $422. In addition, the labor rates charged to the federal award were not reviewed on any of the 60 transactions. Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to ensure payroll costs charged to the federal award are accurate. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-009: U.S. Department of The Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement. Effect: Inaccurate information may be reported and funds may not be drawn on a reimbursement basis. Questioned Costs: None Context/Sampling: A nonstatistical sample of 2 Requests for Reimbursement out of a population of 4 was selected for testing. We noted that there was no evidence of review on one of the Requests for Reimbursement. Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-010: U.S. Department of Interior Direct award and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effect internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The grant awards require the submission of Federal Financial Reports (SF-425) and Performance Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported did not agree to underlying supporting records. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to provide for the documented review and approval of SF-425 reports or Performance Reports. Effect: Inaccurate information was reported to the federal agency on the SF-425 and inaccurate information was reported to the pass-through entity on the Performance Reports. Questioned Costs: None Context/Sampling: A non-statistical sample of two SF-425 reports out of a population of four was selected for testing. A non-statistical sample of two Performance Reports out of a population of four was selected for testing. We noted that there was no evidence of review on all four reports tested. Amounts reported on all four reports tested did not agree to underlying support. Errors are noted as follows: SF-425 for Quarter Ended 9/30/2023: SF-425 for Quarter Ended 3/31/2024: Performance Report to TRCD for Quarter End 9/30/2023: Performance Report to TRCD for Quarter End 12/31/2023: Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to provide for the documented review and approval of SF-425 reports and Performance Reports. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-005: U.S. Department of Homeland Security Assistance to Firefighters Grant, 97.044 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards EMW-2022-FG-03975 under assistance listing 97.044 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The grant awards require the submission of Federal Financial Reports (SF-425). Condition: Information reported did not agree to underlying supporting records. Cause: North Lake Tahoe Fire Protection District (the District) did not have adequate internal controls to provide for accurate reporting of the SF-425 report. Effect: Inaccurate information was reported to the federal agency. Questioned Costs: None Context/Sampling: A non-statistical sample of three SF-425 reports out of a population of eight was selected for testing. Amounts reported on one of the three reports tested did not agree to underlying support. An error was noted as follows: SF-425 for Quarter Ended 12/31/2023 for grant EMW-03975: Key Line Item Amount Reported Amount Supported Cash Disbursements $76,855.71 $0 Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to provide for accurate reporting of the SF-425 report. Views of Responsible Officials: North Lake Tahoe Fire Protection District agrees with this finding.
Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Financial Assistance Listing Number: 14.251 Federal Agency: U.S. Department of Housing and Urban Development Award Year: 2024 Grant Award Number: B-23-CP-CA-0240 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal awards in order to provide reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per the Economic Development Initiative Community Project Funding Grant Guide, the requirements of Section 3 of the Housing and Urban Development Act of 1968 found at 24 CFR Part 75 apply to all grant recipients that are awarded $200,000 or more for projects involving housing construction, rehabilitation, or other public construction. Condition: We identified one (1) project, “Courtplace”, in which Section 3 requirements are applicable to the City. The City was unable to provide supporting documentation to demonstrate that Section 3 requirements were communicated and followed by the applicable project contractor. Cause: The City did not have effective controls in place to ensure all compliance requirements were met. Effect: The City is not in compliance with Section 3 of the Housing and Urban Development Act of 1968 found at 24 CFR Part 75. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A sample of one (1) out of one (1) applicable contractor was selected for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City implement additional policies and procedures to ensure that Section 3 of the Housing and Urban Development Act of 1968 found at 24 CFR Part 75 requirements are complied with. Views of Responsible Official: Management agrees. See separately issued Corrective Action Plan.