Finding 10240 (2023-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-01-26
Audit: 13897
Organization: Heritage University (WA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University has a material weakness in internal controls over compliance, leading to late and inaccurate reporting of HEERF fund usage.
  • Impacted Requirements: Reports were not timely posted, lacked consistent records, and did not show documented reviews, violating compliance with federal reporting standards.
  • Recommended Follow-Up: Update reports to reflect accurate expenditures, ensure separate quarterly postings, maintain submission dates, and implement documented reviews by a supervisor.

Finding Text

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

Categories

Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 10234 2023-002
    Material Weakness Repeat
  • 10235 2023-002
    Material Weakness Repeat
  • 10236 2023-002
    Material Weakness Repeat
  • 10237 2023-003
    Significant Deficiency Repeat
  • 10238 2023-003
    Significant Deficiency Repeat
  • 10239 2023-004
    Material Weakness Repeat
  • 10241 2023-004
    Material Weakness Repeat
  • 10242 2023-005
    Significant Deficiency Repeat
  • 10243 2023-005
    Significant Deficiency Repeat
  • 10244 2023-005
    Significant Deficiency Repeat
  • 10245 2023-006
    Material Weakness Repeat
  • 10246 2023-006
    Material Weakness Repeat
  • 10247 2023-006
    Material Weakness Repeat
  • 10248 2023-007
    Significant Deficiency Repeat
  • 10249 2023-007
    Significant Deficiency Repeat
  • 10250 2023-008
    Material Weakness
  • 10251 2023-008
    Material Weakness
  • 10252 2023-008
    Material Weakness
  • 10253 2023-009
    Significant Deficiency
  • 10254 2023-009
    Significant Deficiency
  • 10255 2023-009
    Significant Deficiency
  • 10256 2023-009
    Significant Deficiency
  • 10257 2023-005
    Significant Deficiency Repeat
  • 10258 2023-005
    Significant Deficiency Repeat
  • 10259 2023-010
    Significant Deficiency
  • 586676 2023-002
    Material Weakness Repeat
  • 586677 2023-002
    Material Weakness Repeat
  • 586678 2023-002
    Material Weakness Repeat
  • 586679 2023-003
    Significant Deficiency Repeat
  • 586680 2023-003
    Significant Deficiency Repeat
  • 586681 2023-004
    Material Weakness Repeat
  • 586682 2023-004
    Material Weakness Repeat
  • 586683 2023-004
    Material Weakness Repeat
  • 586684 2023-005
    Significant Deficiency Repeat
  • 586685 2023-005
    Significant Deficiency Repeat
  • 586686 2023-005
    Significant Deficiency Repeat
  • 586687 2023-006
    Material Weakness Repeat
  • 586688 2023-006
    Material Weakness Repeat
  • 586689 2023-006
    Material Weakness Repeat
  • 586690 2023-007
    Significant Deficiency Repeat
  • 586691 2023-007
    Significant Deficiency Repeat
  • 586692 2023-008
    Material Weakness
  • 586693 2023-008
    Material Weakness
  • 586694 2023-008
    Material Weakness
  • 586695 2023-009
    Significant Deficiency
  • 586696 2023-009
    Significant Deficiency
  • 586697 2023-009
    Significant Deficiency
  • 586698 2023-009
    Significant Deficiency
  • 586699 2023-005
    Significant Deficiency Repeat
  • 586700 2023-005
    Significant Deficiency Repeat
  • 586701 2023-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.77M
84.063 Federal Pell Grant Program $2.61M
84.031 Higher Education_institutional Aid $720,353
84.149 Migrant Education_college Assistance Migrant Program $471,416
84.141 Migrant Education_high School Equivalency Program $464,776
84.042 Trio_student Support Services $298,722
47.074 Biological Sciences $159,648
84.217 Trio_mcnair Post-Baccalaureate Achievement $133,446
84.033 Federal Work-Study Program $111,988
84.007 Federal Supplemental Educational Opportunity Grants $106,506
84.215 Fund for the Improvement of Education $64,806
84.425 Education Stabilization Fund $44,646
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $43,378
84.184 Safe and Drug-Free Schools and Communities_national Programs $41,814
10.558 Child and Adult Care Food Program $37,872
93.011 National Organizations of State and Local Officials $27,151
43.001 Science $20,010
10.310 Agriculture and Food Research Initiative (afri) $18,577
47.076 Education and Human Resources $15,699
93.732 Mental and Behavioral Health Education and Training Grants $8,757
45.164 Promotion of the Humanities_public Programs $8,468
45.024 Promotion of the Arts_grants to Organizations and Individuals $5,000
45.129 Promotion of the Humanities_federal/state Partnership $2,297
84.038 Federal Perkins Loan Rogram $0