Federal Agencies: US Department of Energy (DOE); and US Health and Human Services (HHS Program Names: Research & Development Cluster: Office of Science and Financial Assistance Program; Health Center Program Cluster; and HIV-Related Training and Technical Assistance Program ALN #s: 81.049; 93.224; and 93.145 Award Numbers: DOE DE-SC0018420; and 675 HRSA 5U1OHA29293-07; Federal Award Year 2022 - 2023 Questioned Costs: None 2023-006. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and did not have controls in place to prevent late payments. Out of twelve subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, seven payments (58%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 34-197 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of fourteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster and HIV-Related Training and Technical Assistance Program, three payments (21%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 37-51 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. University of Illinois Urbana-Champaign officials stated continued staffing issues and the multi-layered review and approval process contributed to untimely subrecipient payments. University of Illinois Chicago officials stated the administering unit was delayed in submitting invoices due to competing priorities. Additionally, the central approving offices contributed to the delay in one payment due to fiscal year-end close responsibilities. Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2023-006; 2022-008) 2023-006. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans ALN #: 84.268 Award Numbers: N/A; Federal Award Year 2022 - 2023 Questioned Costs: None 2023-007. Finding: Errors in Reporting for NSLDS The University of Illinois Chicago did not properly report an enrollment change for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Out of the twenty students tested at the University of Illinois Chicago, we noted two (10%) students in which the University did not report the correct enrollment effective date to the NSLDS at the Program-Level. The sample was not intended to be, and was not, a statistically valid sample. The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as student’s Campus-Level enrollment status for all programs the student is enrolled in at a location, even if the student is not currently taking coursework which applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for the program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. University officials stated there was a production defect with the version of the NSLDS reporting process the University was running which caused the wrong enrollment status to be reported. If the NSLDS system is not updated with the student information, overawards could occur should the student transfer to another institution and the student may not properly enter the repayment period. (Finding Code No. 2023-007; 2022-006; 2021-010; 2020-006) 2023-007. Finding: Errors in Reporting for NSLDS (Continued) Recommendation: We recommend the University of Illinois Chicago review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. University Response: Accepted. The defect was corrected June 4, 2023, after the last spring 2023 transmission.
Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans and Federal Pell Grant Program ALN #: 84.063 and 84.268 Award Numbers: N/A; Federal Award Year 2022 - 2023 Questioned Costs: $681 2023-008. Finding: Error in Return of Title IV Funds Calculation The University of Illinois Urbana-Champaign did not use the correct withdrawal date in the return of Title IV funds calculation for a student, which resulted in a shortage of $681 due to the Department of Education. The University’s internal control related to the review of return of Title IV funds did not identify the data entry error. Out of the fifteen students tested at the University of Illinois Urbana-Champaign, we noted one (7%) student in which the return of Title IV funds calculation was performed incorrectly. The sample was not intended to be, and was not, a statistically valid sample. According to the Code of Federal Regulations (34 CFR 668.22), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the student's withdrawal date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of Title IV calculations are performed accurately. University officials stated a data entry error occurred when inputting the effective withdrawal date in the student information system. The use of incorrect withdrawal dates in the return of Title IV funds calculations could result in the need to return additional funds to the Department of Education or to the student. (Finding Code No. 2023-008) Recommendation: We recommend the University of Illinois Urbana-Champaign review current processes for the return of Title IV funds calculations and implement procedures to ensure calculations are done accurately. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans and Federal Pell Grant Program ALN #: 84.063 and 84.268 Award Numbers: N/A; Federal Award Year 2022 - 2023 Questioned Costs: $681 2023-008. Finding: Error in Return of Title IV Funds Calculation The University of Illinois Urbana-Champaign did not use the correct withdrawal date in the return of Title IV funds calculation for a student, which resulted in a shortage of $681 due to the Department of Education. The University’s internal control related to the review of return of Title IV funds did not identify the data entry error. Out of the fifteen students tested at the University of Illinois Urbana-Champaign, we noted one (7%) student in which the return of Title IV funds calculation was performed incorrectly. The sample was not intended to be, and was not, a statistically valid sample. According to the Code of Federal Regulations (34 CFR 668.22), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the student's withdrawal date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of Title IV calculations are performed accurately. University officials stated a data entry error occurred when inputting the effective withdrawal date in the student information system. The use of incorrect withdrawal dates in the return of Title IV funds calculations could result in the need to return additional funds to the Department of Education or to the student. (Finding Code No. 2023-008) Recommendation: We recommend the University of Illinois Urbana-Champaign review current processes for the return of Title IV funds calculations and implement procedures to ensure calculations are done accurately. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agency: US Department of Education (ED) Program Name: Elementary and Second School Emergency Relief Fund ALN #: 84.425D Award Numbers: 826 DOE ISBE Loyola Partnership; Federal Award Year 2022 - 2023 Questioned Costs: N/A 2023-009. Finding: Lack of Subrecipient Monitoring The University of Illinois Springfield did not properly perform required subrecipient monitoring procedures on a certain subrecipient and the internal controls in place failed to ensure all monitoring procedures were performed. For one out of two subrecipients tested, the University of Illinois Springfield did not properly perform subrecipient monitoring procedures. The incorrect agreement template was used which did not allow for the required data elements and a risk evaluation was not performed in order to ensure accountability of for-profit subrecipients under the Education Stabilization Fund. Uniform Grant Guidance (2 CFR 200.331 and 2 CFR 200.332) requires all pass-through entities to: identify the award and applicable requirements, evaluate risk, monitor the activities of the subrecipient, and ensure accountability of for-profit subrecipients. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that subrecipient monitoring is performed over all subawards. University officials stated due to staff turnover and workload, the agreement template issued was incorrect and a risk assessment was not conducted for the subrecipient. Lack of properly documented evidence of subrecipient monitoring policies and procedures may result in the loss of future funding. (Finding Code No. 2023-009) Recommendation: We recommend the University of Illinois Springfield review current processes and procedures to ensure subrecipient monitoring is performed for all subawards. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agency: US Department of Education (ED) Program Name: Elementary and Second School Emergency Relief Fund ALN #: 84.425D Award Numbers: 826 DOE ISBE Loyola Partnership; Federal Award Year 2022 - 2023 Questioned Costs: N/A 2023-009. Finding: Lack of Subrecipient Monitoring The University of Illinois Springfield did not properly perform required subrecipient monitoring procedures on a certain subrecipient and the internal controls in place failed to ensure all monitoring procedures were performed. For one out of two subrecipients tested, the University of Illinois Springfield did not properly perform subrecipient monitoring procedures. The incorrect agreement template was used which did not allow for the required data elements and a risk evaluation was not performed in order to ensure accountability of for-profit subrecipients under the Education Stabilization Fund. Uniform Grant Guidance (2 CFR 200.331 and 2 CFR 200.332) requires all pass-through entities to: identify the award and applicable requirements, evaluate risk, monitor the activities of the subrecipient, and ensure accountability of for-profit subrecipients. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that subrecipient monitoring is performed over all subawards. University officials stated due to staff turnover and workload, the agreement template issued was incorrect and a risk assessment was not conducted for the subrecipient. Lack of properly documented evidence of subrecipient monitoring policies and procedures may result in the loss of future funding. (Finding Code No. 2023-009) Recommendation: We recommend the University of Illinois Springfield review current processes and procedures to ensure subrecipient monitoring is performed for all subawards. University Response: Accepted. The University will take steps to address the recommendation in this finding.
United States Department of the Treasury Reference Number: 2023-005 Program: 21.023 COVID-19 Emergency Rental Assistance Federal Award Number: ERA-2101123208 & ERAE0280 Type of Finding: Noncompliance; Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Reporting; Special Tests and Provisions Condition: The following conditions were found during audit testing of one ERA1 quarterly report and two ERA2 quarterly reports: 1. DSHA procedures over the reporting did not include the documentation of the preparation and review of quarterly reports selected for testing. 2. The following reports required by the U.S. Treasury were either not submitted timely, or evidence of their submission date was not available: Grant: ERA1, Reporting Quarter: Friday September 30, 2022, Due Date: Wednesday, November 16,2022, Date Submitted: Not Documented. Grant: ERA2, Reporting Quarter: Friday September 30, 2022, Due Date: Friday, December 16,2022, Date Submitted: Not Documented. Grant: ERA2, Reporting Quarter: Friday March 31, 2023, Due Date: Wednesday, May 17,2023, Date Submitted: Wednesday, May 23. 3. Audit testing of a statistical sample of 40 cases processed during the year ended June 30, 2023, revealed that Area Median Income (AMI) percentage was not calculated correctly for two cases. The AMI percentages calculated at the case level are utilized to support required demographic reporting. 4. Supporting documentation was not retained for information on the reports selected for testing. A review of the reports selected for testing revealed the following: a. The demographic information section of the ERA2 report for the quarter ended March 31, 2023, was not completed. b. The ERA2 report for the quarter ended September 30, 2022, reported administrative expenditures as $7,770,634 which was the amount of ERA award funds approved for participant households. Audit procedures determined that administrative expenditures for the quarter ended September 30, 2022, were approximately $123,000. c. The ERA1 and ERA2 reports for the quarter ended September 30, 2022, report the same amounts expended and obligated, except for the input error noted above. A similar finding was noted during the audit of the year ended June 30, 2022. Refer to finding 2022-008. Criteria: United States Department of the Treasury ERA Program Reporting Guidance version 3.2 was issued March 29, 2022, and provides quarterly reporting deadlines as detailed in the condition. 2 CFR § 200.303 requires the implementation of effective internal controls: “Internal controls requires the non-federal entity to 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.” Questioned Costs: None Effect: Reports required by the U.S. Treasury were not submitted timely, accurately, and with contemporaneously prepared supporting documentation. Information necessary for the U.S. Treasury to calculate the required reallocations was not accurately reported on the quarterly reports submitted. Cause: Internal controls over reporting were not appropriately designed, implemented, or operated. DSHA’s internal controls did not capture and report amounts obligated for the operation of the ERA program. The report preparation process utilized reports generated from one application processing system, without taking into account payments processed outside of that system. Recommendation: We recommend DSHA enhance its policies and procedures for preparing and approving required reports prior to submission.
FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls 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 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 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." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, 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 Organization’s management 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, 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. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls 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 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 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." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, 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 Organization’s management 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, 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. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls 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 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 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." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, 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 Organization’s management 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, 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. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: No. Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No. Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Questioned costs: None. Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed. Cause: Due to staff turnover, direct loan reconciliations were not maintained. Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management. Repeat finding: No. Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Questioned costs: None. Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days. Cause: Due to staff turnover, stale checks were not being monitored. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No. Recommendation: We recommend that the University review processes to track Title IV refund checks Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Questioned costs: None. Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days. Cause: Due to staff turnover, stale checks were not being monitored. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No. Recommendation: We recommend that the University review processes to track Title IV refund checks Views of responsible officials: There is no disagreement with the audit finding.