Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None Context: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Cause: The College did not have a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.
Department of Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grants – Guaranteed Loan Special Test and Provisions Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The commitment letter for the term loan with the bank requires debt service coverage ratio and working capital to be calculated yearly using audited financial statements. Condition: Management does not have a formally documented review and approval process in place to ensure compliance with the debt service coverage ratio and working capital calculations. Cause: The Health Center calculated the annual debt service coverage ratio as of year‐end and the year‐end financial statements provided the current assets and current liabilities for the working capital calculation; however, there was no formally documented review and approval in place. Effect: The Health Center may have errors in the calculations or be in violation of the debt service coverage ratio and working capital requirements if there is no formal documented review or approval. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: Yes, similar Finding 2023‐003 Recommendation: We recommend management implement a formal documented review and approval process to monitor the debt service coverage ratio and working capital as a part of their year‐end close process to ensure all covenants of the loan are met. Views of Responsible Officials: Management agrees with the finding.
Finding 2024-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Work Study Program: 84.033 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Numbers: P063P232988, P268K242988, P033A231227, P007A231227 Condition For three out of sixty students tested (5%) who had enrollment changes at the College, the students’ status effective dates at the campus level and program level were not reported to the National Student Loan Data System (NSLDS) accurately. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The College reported the three students to the NSLDS within the 60 day requirement; however, the College used the last day of the term as the effective date instead of the last day of attendance. Prevalence Infrequent. Three out of sixty students selected for testing. Effect Failure to report status changes accurately is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement review procedures to ensure that the proper effective date is being reported to the NSLDS when a student withdraws or has an enrollment status change. A system of review procedures and/or controls will ensure the College is reporting status changes accurately. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Work Study Program: 84.033 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Numbers: P063P232988, P268K242988, P033A231227, P007A231227 Condition For three out of sixty students tested (5%) who had enrollment changes at the College, the students’ status effective dates at the campus level and program level were not reported to the National Student Loan Data System (NSLDS) accurately. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The College reported the three students to the NSLDS within the 60 day requirement; however, the College used the last day of the term as the effective date instead of the last day of attendance. Prevalence Infrequent. Three out of sixty students selected for testing. Effect Failure to report status changes accurately is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement review procedures to ensure that the proper effective date is being reported to the NSLDS when a student withdraws or has an enrollment status change. A system of review procedures and/or controls will ensure the College is reporting status changes accurately. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Work Study Program: 84.033 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Numbers: P063P232988, P268K242988, P033A231227, P007A231227 Condition For three out of sixty students tested (5%) who had enrollment changes at the College, the students’ status effective dates at the campus level and program level were not reported to the National Student Loan Data System (NSLDS) accurately. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The College reported the three students to the NSLDS within the 60 day requirement; however, the College used the last day of the term as the effective date instead of the last day of attendance. Prevalence Infrequent. Three out of sixty students selected for testing. Effect Failure to report status changes accurately is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement review procedures to ensure that the proper effective date is being reported to the NSLDS when a student withdraws or has an enrollment status change. A system of review procedures and/or controls will ensure the College is reporting status changes accurately. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Work Study Program: 84.033 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Numbers: P063P232988, P268K242988, P033A231227, P007A231227 Condition For three out of sixty students tested (5%) who had enrollment changes at the College, the students’ status effective dates at the campus level and program level were not reported to the National Student Loan Data System (NSLDS) accurately. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The College reported the three students to the NSLDS within the 60 day requirement; however, the College used the last day of the term as the effective date instead of the last day of attendance. Prevalence Infrequent. Three out of sixty students selected for testing. Effect Failure to report status changes accurately is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement review procedures to ensure that the proper effective date is being reported to the NSLDS when a student withdraws or has an enrollment status change. A system of review procedures and/or controls will ensure the College is reporting status changes accurately. Views of responsible officials We agree with this finding. See corrective action plan.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-004: Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19 - Governor’s Emergency Education Relief Fund), 84.425D (COVID-19 - Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-004: Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19 - Governor’s Emergency Education Relief Fund), 84.425D (COVID-19 - Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-004: Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19 - Governor’s Emergency Education Relief Fund), 84.425D (COVID-19 - Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
2024-004: Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19 - Governor’s Emergency Education Relief Fund), 84.425D (COVID-19 - Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19 - American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: Management agrees with this finding.
2024-005: Reporting—Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop controls to reasonably ensure a thorough review of these reports is performed prior to submission, and maintain documentation supporting this review. View of responsible officials: Management agrees with this finding.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . .” 2 CFR 200.320 states in part: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . “ 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish internal controls enabled noncompliance to go undetected. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation’s policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation’s contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance was systemic issues throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include documenting the procurement process taken by management for transactions with vendors exceeding the simplified acquisition and small purchase thresholds. When utilizing vendors providing specialized services, documentation should be prepared and maintained by management to support sole source procurement decisions when competitive is limited due to the nature of the service. We also recommend implement an annual control to review and document suspension and debarment checks for all vendors funded with Child Nutrition Cluster grant funds that meet the covered transaction threshold of $25,000. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . .” 2 CFR 200.320 states in part: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . “ 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish internal controls enabled noncompliance to go undetected. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation’s policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation’s contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance was systemic issues throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include documenting the procurement process taken by management for transactions with vendors exceeding the simplified acquisition and small purchase thresholds. When utilizing vendors providing specialized services, documentation should be prepared and maintained by management to support sole source procurement decisions when competitive is limited due to the nature of the service. We also recommend implement an annual control to review and document suspension and debarment checks for all vendors funded with Child Nutrition Cluster grant funds that meet the covered transaction threshold of $25,000. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . .” 2 CFR 200.320 states in part: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . “ 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish internal controls enabled noncompliance to go undetected. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation’s policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation’s contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance was systemic issues throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include documenting the procurement process taken by management for transactions with vendors exceeding the simplified acquisition and small purchase thresholds. When utilizing vendors providing specialized services, documentation should be prepared and maintained by management to support sole source procurement decisions when competitive is limited due to the nature of the service. We also recommend implement an annual control to review and document suspension and debarment checks for all vendors funded with Child Nutrition Cluster grant funds that meet the covered transaction threshold of $25,000. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . .” 2 CFR 200.320 states in part: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . “ 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish internal controls enabled noncompliance to go undetected. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation’s policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation’s contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance was systemic issues throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include documenting the procurement process taken by management for transactions with vendors exceeding the simplified acquisition and small purchase thresholds. When utilizing vendors providing specialized services, documentation should be prepared and maintained by management to support sole source procurement decisions when competitive is limited due to the nature of the service. We also recommend implement an annual control to review and document suspension and debarment checks for all vendors funded with Child Nutrition Cluster grant funds that meet the covered transaction threshold of $25,000. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Criteria: According to federal regulations 34CFR 674.19, institutions must retain an original or electronically signed Master Promissory Note for at least three years after all loans made under the Master Promissory Note are satisfied. In addition, 2CFR 200.303 requires the entity to maintain internal controls to provide reasonable assurance that the entity is managing the Federal award in compliance with Federal statues, regulations and the terms and conditions of the Federal award. Condition: During testing of Perkins Loan Recordkeeping and Record Retention, we identified that the University could not provide a signed promissory note for five out of 25 loans selected for testing. Cause: The absence of signed forms may be due to inadequate oversight in the loan documentation process or a lapse in following established procedures for collecting and retaining signed forms. Effect: The lack of signed Perkins Loan forms in the files could result in non-compliance with federal regulations and creates challenges in enforcing loan agreements. Questioned Costs: None Context: During testing of Perkins Loan Recordkeeping and Record Retention we identified that the University could not provide a signed promissory note for five out of 25 loans (20%) selected for testing. The account status was current with ongoing payments for all five loans. Repeat Finding: No Recommendation: It is recommended that the institution reviews and strengthens its procedures for collecting and retaining signed promissory notes. This may include a review of all outstanding Perkins loan borrowers and review of related documentation to ensure a Master Promissory Note has been signed and retained. View of responsible individuals: Management understands the recommendation and the need to retain the records of former students. While we are certain that required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance that the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students.
Finding 2024-002 – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Number: P063P, P007A Condition During our testing of students who withdrew from City Colleges we noted the following exceptions: For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Criteria CFR section 685.309 and 690.83(b)(2) requires City Colleges to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure accurate reporting of enrollment status changes. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Prevalence Infrequent. Four out of sixty students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend City Colleges implement monitoring procedures which will promptly notify the financial aid office of any student status changes. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender accurately. City Colleges should implement a review process to ensure all status changes are addressed by the financial aid office. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-002 – Enrollment Reporting Repeat Finding: Yes Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2023-2024 Award Number: P063P, P007A Condition During our testing of students who withdrew from City Colleges we noted the following exceptions: For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Criteria CFR section 685.309 and 690.83(b)(2) requires City Colleges to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure accurate reporting of enrollment status changes. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Prevalence Infrequent. Four out of sixty students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend City Colleges implement monitoring procedures which will promptly notify the financial aid office of any student status changes. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender accurately. City Colleges should implement a review process to ensure all status changes are addressed by the financial aid office. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-003 – Reporting Repeat Finding: No Federal Program Title – U.S. Department of Health and Human Services Child Care and Development Block Grant (93.575) U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (21.027) Federal Award Year 2023-2024 Award Numbers: 684-05-2840, 420-27-2731, 684-05-2866 Pass Through Entities: Illinois Community College Board, Illinois Department of Commerce and Economic Opportunity, Illinois State Board of Education Condition During our testing of quarterly and annual reports required to be submitted, we noted all reports were submitted and contained accurate information, however: For four of the twelve (33.3%) reports tested for the Child Care and Development Block Grant program, City Colleges did not timely submit certain quarterly reports to the grantor. Reports were submitted between one to thirty days late. For four of the fifteen (26.7%) reports tested for the Coronavirus State and Local Fiscal Recovery Funds, City Colleges did not timely submit certain quarterly and close-out reports to the grantor. Reports were submitted between one to two days late. Criteria Per the grant agreements for the Child Care and Development Block Grant and the Coronavirus State and Local Fiscal Recovery Funds, City Colleges is required to submit quarterly reports along with a final close-out report, which are all required to be submitted within 30 days of the period end. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure timely reporting of required reports. Questioned Costs There were no questioned costs related to testing of reporting. Cause Submission delays were a result of poor time management and breakdowns in communication between PIs, grantor, and the District Office Institutional Resource Development Team. Prevalence Frequent. Four out of twelve reports (33.3%) tested for the Child Care and Development Block Grant program and four out of fifteen (26.7%) reports for the Coronavirus State and Local Fiscal Recovery Funds. Effect Failure to submit reports timely is noncompliance with the requirements of the grant award and could result in loss of funding or other penalties. Recommendation We recommend City Colleges implement monitoring procedures to ensure that reports are submitted in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-003 – Reporting Repeat Finding: No Federal Program Title – U.S. Department of Health and Human Services Child Care and Development Block Grant (93.575) U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (21.027) Federal Award Year 2023-2024 Award Numbers: 684-05-2840, 420-27-2731, 684-05-2866 Pass Through Entities: Illinois Community College Board, Illinois Department of Commerce and Economic Opportunity, Illinois State Board of Education Condition During our testing of quarterly and annual reports required to be submitted, we noted all reports were submitted and contained accurate information, however: For four of the twelve (33.3%) reports tested for the Child Care and Development Block Grant program, City Colleges did not timely submit certain quarterly reports to the grantor. Reports were submitted between one to thirty days late. For four of the fifteen (26.7%) reports tested for the Coronavirus State and Local Fiscal Recovery Funds, City Colleges did not timely submit certain quarterly and close-out reports to the grantor. Reports were submitted between one to two days late. Criteria Per the grant agreements for the Child Care and Development Block Grant and the Coronavirus State and Local Fiscal Recovery Funds, City Colleges is required to submit quarterly reports along with a final close-out report, which are all required to be submitted within 30 days of the period end. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure timely reporting of required reports. Questioned Costs There were no questioned costs related to testing of reporting. Cause Submission delays were a result of poor time management and breakdowns in communication between PIs, grantor, and the District Office Institutional Resource Development Team. Prevalence Frequent. Four out of twelve reports (33.3%) tested for the Child Care and Development Block Grant program and four out of fifteen (26.7%) reports for the Coronavirus State and Local Fiscal Recovery Funds. Effect Failure to submit reports timely is noncompliance with the requirements of the grant award and could result in loss of funding or other penalties. Recommendation We recommend City Colleges implement monitoring procedures to ensure that reports are submitted in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2024-003 – Reporting Repeat Finding: No Federal Program Title – U.S. Department of Health and Human Services Child Care and Development Block Grant (93.575) U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (21.027) Federal Award Year 2023-2024 Award Numbers: 684-05-2840, 420-27-2731, 684-05-2866 Pass Through Entities: Illinois Community College Board, Illinois Department of Commerce and Economic Opportunity, Illinois State Board of Education Condition During our testing of quarterly and annual reports required to be submitted, we noted all reports were submitted and contained accurate information, however: For four of the twelve (33.3%) reports tested for the Child Care and Development Block Grant program, City Colleges did not timely submit certain quarterly reports to the grantor. Reports were submitted between one to thirty days late. For four of the fifteen (26.7%) reports tested for the Coronavirus State and Local Fiscal Recovery Funds, City Colleges did not timely submit certain quarterly and close-out reports to the grantor. Reports were submitted between one to two days late. Criteria Per the grant agreements for the Child Care and Development Block Grant and the Coronavirus State and Local Fiscal Recovery Funds, City Colleges is required to submit quarterly reports along with a final close-out report, which are all required to be submitted within 30 days of the period end. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure timely reporting of required reports. Questioned Costs There were no questioned costs related to testing of reporting. Cause Submission delays were a result of poor time management and breakdowns in communication between PIs, grantor, and the District Office Institutional Resource Development Team. Prevalence Frequent. Four out of twelve reports (33.3%) tested for the Child Care and Development Block Grant program and four out of fifteen (26.7%) reports for the Coronavirus State and Local Fiscal Recovery Funds. Effect Failure to submit reports timely is noncompliance with the requirements of the grant award and could result in loss of funding or other penalties. Recommendation We recommend City Colleges implement monitoring procedures to ensure that reports are submitted in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency. Compliance Not Material Document judgment for your assessment See line 28 for more detailed response Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known 12,965.60 Likely 333907.5 Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The University could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance N/A - I/C Finding Only Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition The University did not review scholarship awards made with federal program funds. Questioned costs: N/A Known Likely Context During our testing of 8 scholarship transactions, we observed 8 instances where scholarship awards did not have evidence of review prior to the award of funds to students. Cause The University did adhere to existing controls in place to review the federal program scholarship awards. Effect Scholarships may be awarded that are disallowed from program funds and may go undetected for substantial periods of time. Repeat Finding No Recommendation We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Identification of the Federal Program: United States Agency for International Development (USAID) Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Award Number: 720BHA24GR00016 Award Period: December 15, 2023 through December 31, 2026 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant granter than or equal to $30,000. Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024. Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report. Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports. Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024. Repeat Finding: This finding is not a repeat finding. Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location. Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name - 97.039, Department of Homeland Security, FEMA Hazard Mitigation Grant Federal Award Identification Number and Year - Not applicable Pass through Entity - Michigan State Police Finding Type - Material weakness and material noncompliance with laws and regulations Criteria - Per 2 CFR 200.303(a) - The recipient and subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - There is no evidence of review of the reports submitted to the funding agency. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Based on the grant award date, the City submitted three quarterly reports. There was no evidence that the reports were reviewed prior to submission. Cause and Effect - The reports were not reviewed for completeness and accuracy prior to submission, and, as a result, the year end quarterly report included costs that were estimated to be 25 percent of the grant award rather than the actual costs incurred to date. Recommendation - The City should implement controls to ensure that reports are reviewed for completeness and accuracy prior to submission to the funding agency. Views of Responsible Officials and Corrective Action Plan - The City has implemented controls to have a secondary review of reports prior to submission to the funding agency.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2024-003 Information on the federal program: Subject: Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $9,498 Context: Two vouchers, in a sample of twenty-one vouchers selected for testing, were for an unallowable activity and unallowable costs. The vouchers related to transportation for students to Kings Island as an incentive for students who demonstrated that they were proficient in workplace skills such as attendance, emotion management, other soft skills. The two Kings Island vouchers tested were the only Kings Island vouchers in the population. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements to ensure only allowable costs are charged to the grant award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.