Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Item 2024-001 – Internal Controls over Federal Programs Significant Deficiency Federal Program – Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing Number – 93.566 Federal Award Number – 8309026721 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Oklahoma Department of Human Services Criteria: 2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition/context: Formal controls were not followed surrounding the following compliance requirement specified for this grant under 2 CFR Part 200, Appendix XI: Activities allowed or unallowed and allowable cost principles – payroll expenditures submitted for reimbursement included the allocation of an employee twice. Cause: A deficiency in the Organization's internal control policies resulted in inaccurate payroll expenditures submitted for reimbursement. Effect: Payroll expenditures charged to the grant were overbilled by $31,565. Questioned cost: $31,565 Repeat finding: This is not a repeat finding. Recommendation: The Organization should enhance existing internal control policies to ensure the accuracy of payroll expenditures being charged to the grant. View of responsible officials: Management's response is reported in "Corrective Action Plan" at the end of this report.
2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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/Context: For one of five vendors selected for testing, the Board was unable to provide documentation that it had verified the suspension and debarment status before entering into covered transactions with the vendor. Questioned Costs: There are no questioned costs related to this finding as the vendor was not federally suspended or debarred. Cause: The Board’s procedures and internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: There is no disagreement with the finding.
2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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/Context: The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland State Department of Education (MSDE). MSDE utilizes these reports as reimbursement requests and subsequently submits payment to the Board based on reported expenditures. For one of four monthly FSR selected for testing, the August 2023 report, the Board was unable to provide documentation that it had reviewed and approved the report prior to submission to MSDE. Questioned Costs: There are no questioned costs related to this finding as the FSR was properly supported by underlying documentation of the associated expenditures. Cause: The Board did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of the FSR reports until November 2023. Effect: The lack of a formal review and approval process could result in inaccurate amounts reported and reimbursed for the Federal programs. Repeat Finding: NoRecommendation: We recommend that the Board continue with established policies and procedures implemented in November 2023 to ensure that documentation supporting the Board’s review and approval of the monthly FSR reimbursement requests are retained for audit purposes. Views of responsible officials: There is no disagreement with the finding.
2024-002 Internal Control over Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Identification of the Federal Program: Federal Agency: United States Housing & Urban Development Program Name: Community Development Block Grant - Disaster Recovery Whole Community Resilience Planning Program Assistance Listing Number: 14.228 Award Number: B-17-DM-72-0001 Passthrough Entity: Government of Puerto Rico Department of Housing Pass-Through Entity Identifying Number: FFNMUBT6WCM1 Sub-award Period: 1/30/2023-9/30/2024 Criteria - The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During the audit, we noted that the Trust has a system of internal control in whichemployees who charge time to the Federal programs, are required to complete a timeslip and have their Timeslips reports reviewed and approved by the employees’ supervisors on a monthly basis. During our testing, we noted that five out of seven employees selected for testing charged time to the Federal program between July 1, 2023 and April 30, 2024, but the timeslips reports were not reviewed and approved by their supervisors until June 2024. There was a lack of timely approval of hours charged to the federal program by the supervisors. However, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause – The Trust did not follow its documented policies and procedures in place to ensure compliance with the requirements regarding activities allowed or unallowed and allowable costs/cost principles – payroll activities. Effect or Potential Effect - Without timely approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over the recording of time exists. Questioned Costs - None. Context - This is a condition identified based upon our review of the Trust’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding - This is not a repeat finding. Recommendation - We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation, certification, and supervisory approval of time charged to the federal awards. Views of Responsible Officials – Time charged to this program had to be captured both as part of the billing process to the Federal funder, United States Housing and Urban Development (HUD) and through Timeslips system as required by internal policy. Time entries were downloaded from the Timeslips system and formatted for approvals using a time certification form template as required and approved by HUD. Billing to HUD occurs monthly. However, there were significant delays by HUD in reviewing and approving monthly invoices along with frequent changes to the requested documentation needed to substantiate costs. Although internal Timeslips reports were available for review and approval on a monthly basis, the program manager’s approvals were only documented on the time certification form as required by HUD. As a result, evidence of timely approvals on a monthly basis were not available as internal policy states. Procedures will be enforced to ensure that program managers are documenting approvals for hours charged to all federal awards according to both federal and internal policies as required on a monthly basis.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: During our eligibility testing, we identified that 2 out of 38 students who received Pell grants were over awarded and overpaid. The explanation provided indicated that the system packages Pell awards based on the annual award, divides it to calculate per-term disbursements, and then rounds the amounts up or down. CLA recalculated the awards using the annual award and found that the system was incorrectly rounding up, resulting in the over awards. Questioned Costs: None Context: During our eligibility testing of thirty-eight students who received Pell, we noted two students that were over awarded and overpaid in Pell grants. Cause: The software that is used to auto package Pell awards has rounding rules inconsistent with that of the rules outlined in the Federal Student Aid handbook and was rounding amounts up when then it should have been rounded down. Effect: A student received more aid than they were eligible for. Repeat Finding: No. Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, 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, we noted two of the 20 Pell grant disbursements were not reported to COD timely. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned Costs: None Context: During our eligibility testing, we noted two of 20 Pell disbursements were not reported to COD within 15 days of the disbursement date. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding 2023-002. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, 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, we noted two of the 20 Pell grant disbursements were not reported to COD timely. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned Costs: None Context: During our eligibility testing, we noted two of 20 Pell disbursements were not reported to COD within 15 days of the disbursement date. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding 2023-002. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002 – Procurement, Suspension, and Debarment Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.493, Congressional Directives Federal Award Number: 1 CE1HS52357‐01‐00 Federal Award Period of Performance: 09/30/2023–09/29/2026 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Procurement policies required by 2 CFR 200.318-326 were not formally documented. Documentation was not consistently retained evidencing the review and approval of new vendors for suspension and debarment prior to adding them into PeopleSoft, CFNI’s vendor management platform. Management represented that they performed a monthly reconciliation of the number of vendors screened and the number of vendors submitted to the third-party, however, management did not retain evidence of the reviews in fiscal year 2024. CFNI’s third-party contractor for suspension and debarment does not have a SOC 1 (System and Organization Controls Report) report that covers the controls over suspension and debarment services provided. Management did not perform testing over the results of the third-party contractor to assess the accuracy of its procedures. Effect or potential effect: Suspension and debarment results provided by the third-party contractor may not be accurate. As a result, federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For three of 40 new vendors sampled during the fiscal year, the documentation evidencing the review of new vendors for suspension and debarment was not retained. For Assistance Listing No. 93.493, the federal portion of procurement expenditures subject to suspension and debarment review totaled $1,441,622, which represents approximately 61.5% of total federal expenditures of $2,341,797 reported in the SEFA for the year ended June 30, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding from the prior year. Recommendation: CFNI should revise its procurement policies to be in compliance with 2 CFR 200.318-326. CFNI should implement procedures to reperform the testing for a sample of vendors from the third-party suspension and debarment results to ensure the accuracy of the results received. CFNI should formalize the documentation of the reconciliation of the number of vendors screened and the number of vendors submitted to the third-party. CFNI should update its policies and procedures over the new vendor setup process to require supporting documentation related to the suspension and debarment search performed be maintained. Views of responsible officials: The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists, no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Assistance listing number: 10.553 & 10.555 Program title: Child Nutrition Cluster Agency: U.S. Department of Agriculture Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Eligibility Type of Finding: Material noncompliance Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: There were errors in the determination of eligibility of students to receive free and reduced meals. Cause: During the year, there was no second review of the determination of student eligibility to receive free or reduced priced meals. Effect: Due to the lack of effective internal control, errors were noted causing the school to overclaim eligible meals. Questioned costs: $20,578.74 Recommendation: We recommend the School evaluate the key processes, identify risks in existing in the Child Nutrition Cluster and implement internal controls to respond to the identified risks. Views of responsible officials: The School agrees with the finding and will implement the auditor’s recommendation.
Assistance listing number: 10.553 & 10.555 Program title: Child Nutrition Cluster Agency: U.S. Department of Agriculture Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Eligibility Type of Finding: Material noncompliance Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: There were errors in the determination of eligibility of students to receive free and reduced meals. Cause: During the year, there was no second review of the determination of student eligibility to receive free or reduced priced meals. Effect: Due to the lack of effective internal control, errors were noted causing the school to overclaim eligible meals. Questioned costs: $20,578.74 Recommendation: We recommend the School evaluate the key processes, identify risks in existing in the Child Nutrition Cluster and implement internal controls to respond to the identified risks. Views of responsible officials: The School agrees with the finding and will implement the auditor’s recommendation.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2024 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2024 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should 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. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.