Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 individual student where a student's campus-level enrollment status was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 7 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 3. 34 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 4. 1 instance where a student’s program-level enrollment effective date did not match the institutions records. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 40 students with exceptions as described above. 5 students had multiple instances of noncompliance. Cause: The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.
Special Tests – 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program. Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds are never escheated to a state, revert to the institution, or revert to any other third party. Additionally, if a check sent to a student or parent is not returned to the institution and is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of outstanding SFA checks, we identified nine checks outstanding that had not been returned to the Department of Education within 240 days. Questioned costs: Federal Pell Grant - $2,691; Federal Direct Student Loans - $3. Context: Out of our population and sample of nine outstanding SFA checks, we noted all nine had the exception described above. Cause: The University had been under the impression that Pell checks may go stale dated and escheat to the state as unclaimed until an internal auditor informed the School that all Title IV aid is to be returned to the DOE and not allowed to escheat, including the Federal Pell Grant. After the internal audit, it was identified that two of the checks were Direct Loans and not Pell. Effect: The University did not return all SFA funds timely. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: An institution must provide to Department of Education an up-todate URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education. Questioned costs: N/A Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education. Cause: The University was not aware of the requirement and previously personal did not retain applicable support, if completed. Effect: The Department of Education was not provided required information regarding the contract. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of education when required. View of responsible official: The University agrees with the finding.
Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 individual student where a student's campus-level enrollment status was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 7 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 3. 34 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 4. 1 instance where a student’s program-level enrollment effective date did not match the institutions records. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 40 students with exceptions as described above. 5 students had multiple instances of noncompliance. Cause: The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.
Special Tests – 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program. Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds are never escheated to a state, revert to the institution, or revert to any other third party. Additionally, if a check sent to a student or parent is not returned to the institution and is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of outstanding SFA checks, we identified nine checks outstanding that had not been returned to the Department of Education within 240 days. Questioned costs: Federal Pell Grant - $2,691; Federal Direct Student Loans - $3. Context: Out of our population and sample of nine outstanding SFA checks, we noted all nine had the exception described above. Cause: The University had been under the impression that Pell checks may go stale dated and escheat to the state as unclaimed until an internal auditor informed the School that all Title IV aid is to be returned to the DOE and not allowed to escheat, including the Federal Pell Grant. After the internal audit, it was identified that two of the checks were Direct Loans and not Pell. Effect: The University did not return all SFA funds timely. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: An institution must provide to Department of Education an up-todate URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education. Questioned costs: N/A Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education. Cause: The University was not aware of the requirement and previously personal did not retain applicable support, if completed. Effect: The Department of Education was not provided required information regarding the contract. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of education when required. View of responsible official: The University agrees with the finding.
FINDING 2023-002 Subject: COVID-19 - Emergency Connectivity Fund Program - Internal Controls Federal Agency: Federal Communications Commission Federal Program: COVID-19 - Emergency Connectivity Fund Program Assistance Listings Number: 32.009 Federal Award Number and Year (or Other Identifying Number): ECF2190010591 Compliance Requirements: Equipment and Real Property; Special Tests and Provisions - Restricted Purpose Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 18 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to asset inventory and per-user limitations of the devices purchased with Emergency Connectivity Fund (ECF) Program support. For each connected device provided to an individual student the asset inventory must identify: 1. The device or equipment type (i.e., laptop, tablet, mobile hotspot, modem, router); 2. The device or equipment make/model; 3. The device or equipment serial number; 4. The full name of the person whom the device was provided; and 5. The dates the device was loaned out and returned to the school or the date the school was notified that the device was missing, lost or damaged. The School Corporation maintained an asset inventory for the purchased iPads with the identified items noted above; however, the data was input into the asset listing from the equipment invoice by the IT Department without a documented review or oversight process to prevent, or detect and correct, errors. In addition, there was not a documented review or oversight process to ensure each student only received one device. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 19 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Emergency Connectivity Fund Program - Suspension and Debarment Federal Agency: Federal Communications Commission Federal Program: COVID-19 - Emergency Connectivity Fund Program Assistance Listings Number: 32.009 Federal Award Number and Year (or Other Identifying Number): ECF2190010591 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not any documented internal controls. One covered transaction that equaled or exceeded $25,000 was identified. The covered transaction, totaling $1,414,140, was selected for testing. For the one covered transaction, the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 20 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person as the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 47 CFR 54.8(d) states in part: "Effect of suspension and debarment. Unless otherwise ordered, any persons suspended or debarred shall be excluded from activities associated with or related to the schools and libraries support mechanism, . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statuses, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 21 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls related to suspension and debarment procedures to ensure entities are neither suspended nor debarred, or otherwise excluded or disqualified prior to entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, H027A200084, H027A210084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness; Other Matters Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not any documented internal controls. One covered transaction that equaled or exceeded $25,000 was identified. The covered transaction, totaling $163,464, was selected for testing. For the one covered transaction, the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 22 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statuses, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls related to suspension and debarment procedures to ensure entities are neither suspended nor debarred, or otherwise excluded or disqualified prior to entering into any covered transactions. INDIANA STATE BOARD OF ACCOUNTS 23 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 24
FINDING 2023-004 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, H027A200084, H027A210084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness; Other Matters Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not any documented internal controls. One covered transaction that equaled or exceeded $25,000 was identified. The covered transaction, totaling $163,464, was selected for testing. For the one covered transaction, the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 22 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statuses, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls related to suspension and debarment procedures to ensure entities are neither suspended nor debarred, or otherwise excluded or disqualified prior to entering into any covered transactions. INDIANA STATE BOARD OF ACCOUNTS 23 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 24
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-019. Suspension and Debarment Not Verified Before Awarding Contracts Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-022, 2021-022 Upon receiving a Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation, the Utah Board of Higher Education (USHE) neither established internal controls to ensure compliance with federal suspension and debarment requirements for awarded contracts, nor did they verify whether contracted parties were suspended or debarred prior to contracting with the parties. The two contracts awarded by USHE out of 44 contracts reviewed statewide did not check for suspension and debarment requirements prior to the award. The Treasury’s Final Rule General provisions and the Interim Final Rule issued May 17, 2021 states that “payments from the…Funds…will be subject to the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200),” which includes suspension and debarment requirements (see 2 CFR 200.214). Uniform Guidance (2 CFR part 200.303) also requires non-federal entities to “establish and maintain effective internal control…that provides reasonable assurance that the non-federal entity [manages the program] in compliance with…terms and conditions of the federal award.” Given USHE’s inexperience with federal programs, USHE was unaware the suspension and debarment requirements were applicable to its program, and GOPB did not sufficiently communicate applicable federal program requirements. Failure to properly implement controls and review each contracted party for suspension and debarment could result in federally debarred entities receiving grant awards. Recommendations: We recommend GOPB assist agencies, including USHE, to gain an understanding of suspension and debarment requirements and establish effective internal controls to ensure compliance with these requirements. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used previously. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred. Follow-up training on ARPA monitoring was done April 3 and June 7, 2023. GOPB also reviewed Final Rule FAQ 13.15 which clarifies that revenue replacement dollars have different subrecipient monitoring standards, including an exemption from suspension and debarment checks in 2 CFR 200.214.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.
2023-004. Higher Education Emergency Relief Fund Quarterly Reports Not Reviewed for Accuracy Utah Tech University (Finding Type: Significant Deficiency) Federal Agency: Department of Education Assistance Listing Number and Title: 84.425E Higher Education Emergency Relief Fund (HEERF) Student Aid 84.425F HEERF Institutional Aid Federal Award Number: P425E201701, P425F201626, and P425M200131 Questioned Costs: N/A Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: N/A The University did not have a control procedure in place to ensure that its Higher Education Emergency Relief Fund (HEERF) quarterly reports were reviewed for accuracy. Federal regulations (2 CFR 200.303) require that entities “establish and maintain effective internal control…that provides reasonable assurance that the … entity is managing the Federal award in compliance with…terms and conditions of the Federal award.” However, University personnel did not subject the reports to a review and approval process because they did not realize the requirements applied to HEERF quarterly reports. The University should be aware that effective control requirements apply to all federally required reports. Lack of proper controls may result in inaccurate information to be reported without detection that may lead users to reach inappropriate conclusions and make improper decisions. Recommendation: We recommend that the University ensure all required reports of federal financial assistance programs are reviewed to ensure accuracy. University’s Response: We agree with the finding that there should have been secondary internal review of the quarterly HEERF reports. However, it should also be noted that the quarterly reports were carefully reconciled to ensure agreement with the University’s financial ledgers, and the underlying ledger transactions were subject to all pertinent internal controls and approval processes.