Finding 1101101 (2024-001)

FINDING 2024-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Federal Agency: U.S. Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Assistance Listings Numbers: 84.007, 84.033, 84.063, 84.268 Federal Award Number and Year (or Other Identifying Number): FY2024 Compliance Requirement: Special Tests and Provisions - Verification Audit Finding: Material Weakness Condition and Context As a recipient of the Title IV funding from the Federal Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study Program (FWS), Federal Pell Grant Program (Pell), and Federal Direct Student Loans program (direct loan), the University was responsible for designing and implementing effective internal controls. The University had developed a system of internal controls over these federal programs that included policies and procedures related to the Special Tests and Provisions - Verification compliance requirement. The University had designed a key internal control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the internal control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee responsible for performing the verifications was also responsible for reviewing those verifications during the audit period without an independent oversight, review, or approval process involving a second employee. The lack of effective internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the University's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. The system of internal controls, as designed by the University's management, was not properly implemented due to a staffing shortage in the Office of Student Financial Assistance. As a result, the same employee performed and reviewed the required verifications. INDIANA STATE BOARD OF ACCOUNTS 16 UNIVERSITY OF SOUTHERN INDIANA 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. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the University's management properly implement the system of internal controls as designed to ensure compliance with the Special Tests and Provisions - Verification compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.