Finding 1123712 (2024-009)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2025-03-31
Audit: 351580
Organization: Johnson C. Smith University (NC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to provide adequate documentation for student eligibility in the TRIO program, leading to non-compliance with federal requirements.
  • Impacted Requirements: Stipend disbursements exceeded allowed limits, and eligibility criteria for grant aid were not met for some students.
  • Recommended Follow-Up: Enhance internal controls and formalize policies to ensure proper documentation retention and compliance with TRIO program regulations.

Finding Text

Federal Program Information: TRIO Cluster (ALN: 84.042A and 84.047A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Under the Upward Bound (“UB”) program, the University may award stipends of up to $40 per month from September to May of the academic year and $60 for each of the summer months (June, July, and August) to eligible participants. Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that: • These students are at high risk of dropping out; and • It will first meet the needs of all its eligible first- and second-year students for services under this paragraph. Condition: The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends. Cause: Insufficient administrative oversight and internal controls over TRIO program eligibility requirements. Effect or Potential Effect: The University was not in compliance with TRIO program eligibility requirements. Questioned Costs: Known questioned costs: $979; total questioned costs: indeterminable. Context: We noted the following exceptions during our testing: • For 4 of 29 students selected for testing, stipend amounts under the UB program were disbursed to students in excess of the allowed monthly maximum for the academic year. • For 1 of 6 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-007 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required. Views of Responsible Officials: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification. Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response. During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained. Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement. With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals.

Categories

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

Other Findings in this Audit

  • 547245 2024-001
    Significant Deficiency
  • 547246 2024-001
    Significant Deficiency
  • 547247 2024-001
    Significant Deficiency
  • 547248 2024-002
    Significant Deficiency
  • 547249 2024-002
    Significant Deficiency
  • 547250 2024-003
    Significant Deficiency
  • 547251 2024-003
    Significant Deficiency
  • 547252 2024-003
    Significant Deficiency
  • 547253 2024-003
    Significant Deficiency
  • 547254 2024-004
    Significant Deficiency
  • 547255 2024-005
    Significant Deficiency
  • 547256 2024-005
    Significant Deficiency
  • 547257 2024-005
    Significant Deficiency
  • 547258 2024-005
    Significant Deficiency
  • 547259 2024-006
    Significant Deficiency
  • 547260 2024-006
    Significant Deficiency
  • 547261 2024-007
    Significant Deficiency
  • 547262 2024-007
    Significant Deficiency
  • 547263 2024-007
    Significant Deficiency
  • 547264 2024-008
    Material Weakness Repeat
  • 547265 2024-008
    Material Weakness Repeat
  • 547266 2024-008
    Material Weakness Repeat
  • 547267 2024-008
    Material Weakness Repeat
  • 547268 2024-008
    Material Weakness Repeat
  • 547269 2024-008
    Material Weakness Repeat
  • 547270 2024-009
    Significant Deficiency Repeat
  • 547271 2024-009
    Significant Deficiency Repeat
  • 547272 2024-010
    Significant Deficiency Repeat
  • 547273 2024-010
    Significant Deficiency Repeat
  • 547274 2024-010
    Significant Deficiency Repeat
  • 547275 2024-011
    Material Weakness Repeat
  • 547276 2024-011
    Material Weakness Repeat
  • 547277 2024-012
    Significant Deficiency Repeat
  • 547278 2024-012
    Significant Deficiency Repeat
  • 1123687 2024-001
    Significant Deficiency
  • 1123688 2024-001
    Significant Deficiency
  • 1123689 2024-001
    Significant Deficiency
  • 1123690 2024-002
    Significant Deficiency
  • 1123691 2024-002
    Significant Deficiency
  • 1123692 2024-003
    Significant Deficiency
  • 1123693 2024-003
    Significant Deficiency
  • 1123694 2024-003
    Significant Deficiency
  • 1123695 2024-003
    Significant Deficiency
  • 1123696 2024-004
    Significant Deficiency
  • 1123697 2024-005
    Significant Deficiency
  • 1123698 2024-005
    Significant Deficiency
  • 1123699 2024-005
    Significant Deficiency
  • 1123700 2024-005
    Significant Deficiency
  • 1123701 2024-006
    Significant Deficiency
  • 1123702 2024-006
    Significant Deficiency
  • 1123703 2024-007
    Significant Deficiency
  • 1123704 2024-007
    Significant Deficiency
  • 1123705 2024-007
    Significant Deficiency
  • 1123706 2024-008
    Material Weakness Repeat
  • 1123707 2024-008
    Material Weakness Repeat
  • 1123708 2024-008
    Material Weakness Repeat
  • 1123709 2024-008
    Material Weakness Repeat
  • 1123710 2024-008
    Material Weakness Repeat
  • 1123711 2024-008
    Material Weakness Repeat
  • 1123713 2024-009
    Significant Deficiency Repeat
  • 1123714 2024-010
    Significant Deficiency Repeat
  • 1123715 2024-010
    Significant Deficiency Repeat
  • 1123716 2024-010
    Significant Deficiency Repeat
  • 1123717 2024-011
    Material Weakness Repeat
  • 1123718 2024-011
    Material Weakness Repeat
  • 1123719 2024-012
    Significant Deficiency Repeat
  • 1123720 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.89M
84.063 Federal Pell Grant Program $4.74M
11.028 Connecting Minority Communities Pilot Program $2.35M
84.031 Higher Education Institutional Aid $555,668
84.007 Federal Supplemental Educational Opportunity Grants $480,658
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $446,604
84.042 Trio Student Support Services $441,950
84.120 Minority Science and Engineering Improvement $427,368
84.033 Federal Work-Study Program $390,521
93.317 Emerging Infections Programs $363,742
84.217 Trio McNair Post-Baccalaureate Achievement $322,726
84.047 Trio Upward Bound $256,358
47.076 Stem Education (formerly Education and Human Resources) $137,979
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities (hbcus). $63,530
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $51,145
93.310 Trans-Nih Research Support $48,409
45.313 Laura Bush 21st Century Librarian Program $40,928
12.598 Centers for Academic Excellence $32,974
97.062 Scientific Leadership Awards $27,918
84.335 Child Care Access Means Parents in School $23,238
17.268 H-1b Job Training Grants $20,962
97.061 Centers for Homeland Security $17,900
11.417 Sea Grant Support $14,474
54.001 Intelligence Community Centers for Academic Excellence $11,094
89.003 National Historical Publications and Records Grants $6,956
84.425 Education Stabilization Fund $4,647
93.859 Biomedical Research and Research Training $1,550