Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (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. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (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. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (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. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 30 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective system of internal controls was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of five of the journal entries tested. For the one journal entry, we were unable to determine if the Title I fund transfers in, totaling $13,434, and transfers out, totaling $95,115, were for allowable activities and costs for the program. The lack of effective internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 31 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . (g) Be adequately documented. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreements and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $108,549 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Cash Management and Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding related to Reporting from the immediately prior audit report. The prior audit finding number was 2020-007. INDIANA STATE BOARD OF ACCOUNTS 32 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation filed the required special reports with the Indiana Department of Education; however, none of the reports were supported by the School Corporation's records. Although the Title I Director reviewed the requests for reimbursement and the Final Expenditure Reports, the reviews did not ensure that the reports agreed to the School Corporation's financial records. The 2019-2020 and 2020-2021 Final Expenditure Reports and the four reimbursement requests tested could not be traced to the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: . . . "The financial management system of each non-Federal entity must provide for the following: INDIANA STATE BOARD OF ACCOUNTS 33 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.327 Financial reporting. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with requirements related to the Cash Management and the Reporting compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 34 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. Summary data of nonpublic enrollment and poverty was verbally provided to the School Corporation by the participating nonpublic school. The summary data should have been accompanied by a list of students and their poverty (socioeconomic) status as supporting documentation. The School Corporation did not retain the supporting documentation for 2020-2021 and 2021-2022 for the nonpublic school enrollment and poverty data. The lack of internal controls, the failure to retain supporting documentation for nonpublic enrollment and poverty figures, and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 35 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under ? 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." Cause Management had not established a system of internal controls that would have ensured compliance, or that supporting documentation would have been retained and made available for audit, related to the Eligibility compliance requirement. Effect The failure to establish a system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirement listed above. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 36 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Eligibility compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 30 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective system of internal controls was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of five of the journal entries tested. For the one journal entry, we were unable to determine if the Title I fund transfers in, totaling $13,434, and transfers out, totaling $95,115, were for allowable activities and costs for the program. The lack of effective internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 31 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . (g) Be adequately documented. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreements and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $108,549 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Cash Management and Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding related to Reporting from the immediately prior audit report. The prior audit finding number was 2020-007. INDIANA STATE BOARD OF ACCOUNTS 32 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation filed the required special reports with the Indiana Department of Education; however, none of the reports were supported by the School Corporation's records. Although the Title I Director reviewed the requests for reimbursement and the Final Expenditure Reports, the reviews did not ensure that the reports agreed to the School Corporation's financial records. The 2019-2020 and 2020-2021 Final Expenditure Reports and the four reimbursement requests tested could not be traced to the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: . . . "The financial management system of each non-Federal entity must provide for the following: INDIANA STATE BOARD OF ACCOUNTS 33 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.327 Financial reporting. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with requirements related to the Cash Management and the Reporting compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 34 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. Summary data of nonpublic enrollment and poverty was verbally provided to the School Corporation by the participating nonpublic school. The summary data should have been accompanied by a list of students and their poverty (socioeconomic) status as supporting documentation. The School Corporation did not retain the supporting documentation for 2020-2021 and 2021-2022 for the nonpublic school enrollment and poverty data. The lack of internal controls, the failure to retain supporting documentation for nonpublic enrollment and poverty figures, and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 35 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under ? 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." Cause Management had not established a system of internal controls that would have ensured compliance, or that supporting documentation would have been retained and made available for audit, related to the Eligibility compliance requirement. Effect The failure to establish a system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirement listed above. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 36 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Eligibility compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Allowable costs - U.S. Department of Agriculture, Department of Social Services, The Emergency Food Assistance (Food Distribution Cluster), Assistance Listing # 10.565, 10.568 & 10.569, June 30, 2022 Award Year, pass-through State of Missouri Department of Health and Senior Services. Criteria: The Administrative cost grant can only be used for activities intrinsic to the processing, transportation and distribution of the Emergency Food Assistance Program (?TEFAP?) commodities, costs associated with determination of eligibility, costs of recordkeeping, auditing or other administrative procedure required for program participation, or costs involved in publishing announcements of times and locations of distribution. Under 2 CFR 200.403, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federal financed program in either the current or prior period. Under 2 CFR 200.334, non-federal entities are required to retain financial records and supporting documentation for a three-year period from the date of financial reporting to the pass-through entity. Condition: Administrative costs are submitted to the state monthly for reimbursement on the Record of Expenditures under the TEFAP Financial Assistance form (?FD-32D?). The State reimburses the Organization for administrative costs as determined by the state on a monthly basis. Typically, the monthly reimbursement amount is significantly less than the actual amount of allowed administrative expenses incurred by the Organization. During our procedures, we noted that certain expenditures, amounting to approximately $3,290, which were included on the FD-32D of which supporting documentation the Organization is required to retain under 2 CFR part 200 was lacking. As such, we could verify these costs related to activities allowed for reimbursement under 2 CFR part 200. Questioned Costs: None. The monthly reimbursement requests for administrative costs submitted by the Organization exceed the amounts reimbursed by the State and therefore these amounts are not considered to be reimbursed but should not have been included in the monthly submittal as the supporting documentation was unavailable to ensure that the related costs were allowable. Context: Employees with reporting duties for the program are including expenditures that are not substantiated by receipts demonstrating they are allowed under the terms of the grant. Effect: Costs which are possibly unallowable, due to the lack of supporting documentation, are being improperly included on the monthly reporting to the State. It was noted that after excluding these costs from the monthly reports, the actual allowed administrative costs incurred and submitted by the Organization to the State remained greater than the amount reimbursed by the State. Cause: The employees responsible for the preparation of the report did not have the proper information, training and knowledge of the program to ensure that only allowable costs are included on the report. Recommendation: The Organization should review its accounting and reporting policies to ensure that steps are added to include a review for unallowable costs. Identification as a Repeat Finding: This is a repeat of finding 2021-002. Views of Responsible Officials and Corrective Actions See Corrective Action Plan
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
Finding 2022-063 Higher Education Emergency Relief Fund Reporting Compliance Finding The CARES Act was signed into law on March 27, 2020, and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to the (HEERF Program. CRRSAA was signed into law on December 27, 2020 and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. The HEERF Program is one of the subprograms of the federal COVID-19 ? Education Stabilization Fund [ALN 84.425]. The HEERF program contains two portions: the Student Aid Portion [ALN 84.425E] and the Institutional Portion [ALN 84.425F]. Since April 2020, the University has been awarded a total of $86.3 million in HEERF funding. From inception through June 30, 2022, the University spent $35.4 million for the HEERF program Student Aid Portion and $48.9 million for the HEERF program Institutional Portion. The University reports that it will spend the remaining amount of funding during Fiscal Year 2023. The University signed an agreement titled the ?Certification and Agreement? with the U.S. Department of Education (ED) to indicate the University?s acceptance of the HEERF funding and the applicable terms and requirements. Under the HEERF program requirements, there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report, which includes summarized information on the Student Aid and Institutional Portions for the reporting period. The ED specified that Student Aid Portion and Institutional Portion reports needed to be posted to an institution?s website at specified times. The annual report is to be submitted directly to the federal ED. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University had adequate internal controls in place over and complied with HEERF Institutional and Student Aid Portion grant reporting requirements for Fiscal Year 2022. As part of our audit work, we reviewed the University?s internal controls over the HEERF grant reporting requirements. In addition, we tested a sample of 5 of the 8 HEERF reports submitted by the University during Fiscal Year 2022 to determine whether the reports were posted on the University?s primary website or submitted directly to the ED by the federal due dates and complied with federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? For the Student Aid Portion, beginning on May 6, 2020, the ED required institutions to publicly post certain information on their website, including the number of awards distributed to students, the total amount awarded, and the methodologies used by the institution to determine which students receive awards, no later than 30 days after the award date, and to update that information every 45 days thereafter (by posting a new report). ? On August 31, 2020, the ED revised the reporting requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. This revision from every 45 days to a calendar quarter was effective for the first calendar quarter report due by October 10, 2020, and covering the period from after the institution?s last report through the end of the calendar quarter on September 30, 2020. ? For the Institutional Portion, a federal form filled out by the institution must be posted on the institution?s website covering aggregate expenditure amounts for each calendar quarter (September 30, December 31, March 31, and June 30) and concluding after an institution has spent the institutional portion of their HEERF Funds. The institution must post their first report by October 30, 2020, the first quarter of 2021 report by July 20, 2021, and post all other reports no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). ? Section 18004(e) of the CARES Act and Section 314(e) of the CRRSAA require an institution receiving funds under HEERF to submit a report to the Secretary of the ED at ?such time in such a manner as the Secretary may require?. ? Federal regulation [2 CFR 200.334] states that ?financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? The instructions for the Quarterly HEERF Reporting Form notes, ?any changes or updates after the initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the `Date of Report? line.? ? Federal regulation [2 CFR 200.303] states that the University, as a federal grant recipient, must ?establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulation, and the terms and conditions of the Federal award.? The University signed a HEERF Certification and Agreement to accept the funding and acknowledge its responsibilities under the grant; therefore, the University was responsible under the Agreement to ensure that it complied with HEERF reporting and other requirements. What problems did the audit work identify? We determined that 2 out of 5 reports tested (40 percent) did not meet the HEERF grant report posting requirements. Specifically: ? The University did not post the HEERF CRRSAA Student quarterly report for the quarter ending September 30, 2021 on the University?s primary website, as required. ? The University published the HEERF ARP Student quarterly report for the quarter ending March 31, 2022 on May 26, 2022?46 days past the due date of April 10, 2022. No issues were noted on the accuracy of the financial information on this report. Why did these problems occur? The University did not implement adequate internal controls to ensure it complied with the HEERF grant reporting requirements. Specifically, the University did not have appropriate policies and procedures in place to ensure that staff submit the required reports within federally required timeframes. Why do these problems matter? Federal oversight agencies, including ED, depend on accurate reports to measure program results and states? compliance with federal requirements. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the Certification and Agreement. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-063 Metropolitan State University of Denver (University) should strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund (HEERF) reporting requirements by developing and documenting policies and procedures for identifying and researching the specific reporting requirements and ensuring that staff post to the University?s website the required reports within federally required timeframes. In addition, the University should ensure that all the HEERF reports that are currently required to be posted are on the website. Response Metropolitan State University Agree Implementation Date: December 2022 In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.
FINDING 2022-003 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014 FY2021, S010A200014 FY2021 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context Costs charged to grant funds must be adequately documented. To adequately document payroll expenses charged to the grant fund, contracts or other documentation supporting the employees' approved rates of pay are necessary. The School Corporation utilized a financial software system that has two different sides, an employee portal side and an administrator side. Employee contracts are approved by the employee, the Superintendent of Schools, and the President of the School Board within the system on the employee portal side. Once approved, the data in the employee portal side is fed into a process in the administrator side. The School Corporation could not provide contracts for 10 of 15 employees tested, as the contracts were not properly archived in the financial software used to electronically approve and archive employment contracts. As such, we could not verify the employees were paid their contracted rate for hours spent working on grant-related activities. This resulted in known questioned costs of $203,488. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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). . . ." INDIANA STATE BOARD OF ACCOUNTS 24 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (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. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 25 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all employment contracts could be presented for audit nor could documentation be provided to support time charged to the grant. 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 School Corporation. Questioned Costs There were known questioned costs of $203,488 as identified in Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contracts and certifications, as appropriate, are retained to support the amounts paid from Title I program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response The alternative documentation provided was a snapshot from the administrator side of the financial software system; however, the original source document, which was the contract that was approved by the employee, the Superintendent of Schools, and the President of the School Board, was not provided to substantiate the amounts in the administrator side of the financial software system. We reaffirm our finding and will review the status of the finding during our next audit.
FINDING 2022-004 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014 FY2021; S010A200014 FY2021 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context Form 9 Data The State uses the Form 9 data for their required submission of the average state per pupil expenditure data which is submitted to the National Center for Education Statistics. INDIANA STATE BOARD OF ACCOUNTS 26 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The Form 9 reports are comprised of the School Corporation's transactions recorded during the audit period. Payroll reports, which included summary level payroll data, were provided to a knowledgeable employee for review; however, the reports did not include sufficient detail to effectively review and verify the proper employees were paid from the correct fund, account, and object codes. Reimbursement Requests Requests for reimbursement are utilized by the School Corporation to request reimbursement for allowable expenses paid from Title I funds. Requests for reimbursement should be based on and supported by transactions recorded in the Title I funds of the School Corporation. Summary level reports were run from the School Corporation's financial system by the Director of Federal Grants for the period in which reimbursement was requested. The reports were then attached to the reimbursement request. The Title I Director then approved the reimbursement request prior to submission. Of the three reimbursement requests selected for testing, two could not be verified to the summary level detail attached to the reimbursement request nor to a detailed list of transactions. As the amount requested for reimbursement could not be traced to detailed records nor reports which accumulated or summarized the data, the accuracy and completeness of the reimbursement requests could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 27 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's 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, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. 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 School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure detailed supporting documentation is used and retained when reviewing Form 9 data and for all requests for reimbursements submitted on behalf of the Title I program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 30 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Education Stabilization Fund established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. Costs charged to grant funds must be adequately documented. To adequately document payroll expenses charged to the grant fund, contracts or other documentation supporting the employees' approved rates of pay are necessary. The School Corporation utilized a financial software system that has two different sides, an employee portal side and an administrator side. Employee contracts are approved by the employee, the Superintendent of Schools, and the President of the School Board within the system on the employee portal side. Once approved, the data in the employee portal side is fed into a process in the administrator side. The School Corporation could not provide contracts for 3 of 13 employees tested, as the contracts were not properly archived in the financial software used to electronically approve and archive employment contracts. As such, we could not verify the employees were paid their contracted rate for hours spent working on grant-related activities. This resulted in known questioned costs of $26,207. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. INDIANA STATE BOARD OF ACCOUNTS 31 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all employment contracts could be presented for audit nor could documentation be provided to support time charged to the grant. 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 School Corporation. Questioned Costs There were known questioned costs of $26,207 as identified in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contracts and certifications, as appropriate, are retained to support the amounts paid from Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 32 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response The alternative documentation provided was a snapshot from the administrator side of the financial software system; however, the original source document, which was the contract that was approved by the employee, the Superintendent of Schools, and the President of the School Board, was not provided to substantiate the amounts in the administrator side of the financial software system. We reaffirm our finding and will review the status of the finding during our next audit.
FINDING 2022-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The School Corporation submitted three reports during the audit period; however, a single employee prepared and submitted the reports without a review or oversight process in place to prevent or detect and correct errors. Additionally, two of the three reports tested, ESSER I Year 2 and ESSER II Year 1, were not supported by the School Corporation's records. The financial information provided was based on estimates and actual expenditures, and did not agree with the data submitted in the reports, nor to the School Corporation's records; therefore, the reports were determined to be inaccurate and incomplete. The key line item "Overall Expenditures" was tested on both reports. The ESSER I Year 2 report overall expenditures key line item was determined to be understated by $140,160. The ESSER II Year 1 overall expenditures key line item was determined to be overstated by $2,745,818. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 33 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . ." (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. 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 School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 30 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Education Stabilization Fund established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. Costs charged to grant funds must be adequately documented. To adequately document payroll expenses charged to the grant fund, contracts or other documentation supporting the employees' approved rates of pay are necessary. The School Corporation utilized a financial software system that has two different sides, an employee portal side and an administrator side. Employee contracts are approved by the employee, the Superintendent of Schools, and the President of the School Board within the system on the employee portal side. Once approved, the data in the employee portal side is fed into a process in the administrator side. The School Corporation could not provide contracts for 3 of 13 employees tested, as the contracts were not properly archived in the financial software used to electronically approve and archive employment contracts. As such, we could not verify the employees were paid their contracted rate for hours spent working on grant-related activities. This resulted in known questioned costs of $26,207. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. INDIANA STATE BOARD OF ACCOUNTS 31 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all employment contracts could be presented for audit nor could documentation be provided to support time charged to the grant. 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 School Corporation. Questioned Costs There were known questioned costs of $26,207 as identified in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contracts and certifications, as appropriate, are retained to support the amounts paid from Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 32 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response The alternative documentation provided was a snapshot from the administrator side of the financial software system; however, the original source document, which was the contract that was approved by the employee, the Superintendent of Schools, and the President of the School Board, was not provided to substantiate the amounts in the administrator side of the financial software system. We reaffirm our finding and will review the status of the finding during our next audit.
FINDING 2022-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The School Corporation submitted three reports during the audit period; however, a single employee prepared and submitted the reports without a review or oversight process in place to prevent or detect and correct errors. Additionally, two of the three reports tested, ESSER I Year 2 and ESSER II Year 1, were not supported by the School Corporation's records. The financial information provided was based on estimates and actual expenditures, and did not agree with the data submitted in the reports, nor to the School Corporation's records; therefore, the reports were determined to be inaccurate and incomplete. The key line item "Overall Expenditures" was tested on both reports. The ESSER I Year 2 report overall expenditures key line item was determined to be understated by $140,160. The ESSER II Year 1 overall expenditures key line item was determined to be overstated by $2,745,818. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 33 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . ." (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. 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 School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.