Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2 CFR section 200.303(a) requires that non-federal entities 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: The Organization did not consistently document review of payroll reports. Questioned costs: None Context: We tested a sample of 40 payroll disbursements related to this program, noting 3 of the 40 selections did not have a documented review of their payroll report from their third party payroll processor. Cause: Management indicated payroll is reviewed each month, even if it is not initialed. Effect: The effect of this condition increases the possibility that payroll costs submitted for reimbursement may be inaccurate. Repeat Finding: No Recommendation: We recommend the Organization documents review of all payroll reports. Views of Responsible Officials: There is no disagreement with the audit finding.
2 CFR section 200.303(a) requires that non-federal entities 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: The Organization does not have someone reviewing the monthly reimbursement requests prior to the submission. Questioned costs: None Context: We tested all three months of billing in fiscal year 2023, noting there was no review present for any of the months. Cause: Management indicated a review process is not in place. Effect: The effect of this condition increases the possibility that reimbursement requests may contain errors. Repeat Finding: No Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Views of Responsible Officials: There is no disagreement with the audit finding.
2023‐001 Department of the Treasury FFAL #21.027 COVID‐19 ‐ Coronavirus State and Local Fiscal Recovery Funds Applicable Federal Award Number and Year – SLFRP0515 for 2021 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The County’s quarterly Project and Expenditure Reports were not reviewed and approved by a separate individual outside of the preparer. The reports submitted in fiscal year 2023 did not contain obligation and expenditure information for $10,000,000 in revenue replacement expenditures allocated to fiscal year 2023 eligible employee wages. Cause: The County did not have an internal control process in place to ensure a secondary review and approval of the Project and Expenditure Reports. Effect: Without a secondary review and approval, there is a greater possibility that the reports may not be accurately completed. Questioned Costs: None reported. Context: A nonstatistical sample of two out of the four quarterly Project and Expenditure Reports were tested. Repeat Finding from Prior Years: No Recommendation: We recommend the County implement a control process which includes a secondary review and approval of the Project and Expenditure Reports. Views of Responsible Officials: Moving forward, the Finance Director will review and approve the reports prior to being submitted.
Finding 2023-002 – B. Allowable Costs and C. Cash Management Federal Agency: U.S. Department of Health and Human Services Passthrough Entity: Illinois Department of Human Services Assistance Listing Number and Federal Program: 93.671 Family Violence Prevention and Services Criteria: In accordance with 2 CFR 200.303 and the grant agreement, the Organization must establish and maintain effective internal control over the Federal award to provide reasonable assurance the Organization is in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The Organization must have systems in place that provide reasonable assurance that the information is accurate, allowable, and compliance with the terms and conditions of the grant agreement. Statement of Condition: During the course of our audit, we found there is not an internal control in place to ensure the required Periodic Financial Report accurately reflects the records of the Organization. Statement Cause: The Chief Executive Officer signs each Periodic Financial Report after it has been completed by the Chief Finance Officer, however, the proper supporting documentation is not provided to the Chief Executive Officer for review of the Periodic Financial Report prior to submission. Statement of Effect: Without a proper review of the costs being claimed for reimbursement on the Periodic Financial Report, unallowable costs could be claimed or costs could be claimed for which have not been incurred prior to the request for reimbursement. Questioned Costs: No questioned costs were identified. Identification of Repeat Findings: Not a repeat finding. Recommendations: We recommend the Chief Finance Officer provide general ledger detail of the grant expenses to the Chief Executive Officer with the Periodic Finance Report. This will allow another level of review to ensure all costs being claimed for reimbursement have been incurred and are allowable under the grant agreement. Views of Responsible Official(s): The Chief Finance Officer will provide general ledger detail individually by grant to the Chief Executive Officer along with the Periodic Finance Report to review. This process will be reviewed by the Finance Committee and approved by the Quanada Board of Trustees as part of our Fiscal Policy document. See corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: a.The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in §5.1, the following clauses… (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency) 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an internal controls/procedure in place to ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing, the School Corporation did not include the wage-rate requirements in the contract or receive the weekly payroll reports as required. The sample item cost $32,029 to replace a drinking fountain. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in vendor contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. None noted.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: a.The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in §5.1, the following clauses… (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency) 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an internal controls/procedure in place to ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing, the School Corporation did not include the wage-rate requirements in the contract or receive the weekly payroll reports as required. The sample item cost $32,029 to replace a drinking fountain. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in vendor contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. None noted.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: a.The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in §5.1, the following clauses… (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency) 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an internal controls/procedure in place to ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing, the School Corporation did not include the wage-rate requirements in the contract or receive the weekly payroll reports as required. The sample item cost $32,029 to replace a drinking fountain. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in vendor contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. None noted.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.