Finding 1161413 (2024-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-10-24
Audit: 371273
Organization: Wittenberg University (OH)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The University failed to maintain proper documentation and approvals for TRIO program expenditures, risking noncompliance with federal guidelines.
  • Impacted Requirements: Internal controls for spending federal funds must ensure costs are allowable, allocable, and reasonable as per Uniform Guidance.
  • Recommended Follow-Up: Revise internal controls and establish a quality assurance process to ensure all expenditures are properly approved and documented.

Finding Text

Federal Program: TRIO Cluster Federal Assistance Listing Number: 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: According to the Uniform Guidance (2 CFR Part 200) and TRIO program regulations, the University is required to maintain internal controls to ensure federal funds are spent on allowable, allocable, and reasonable expenses that directly support the objectives of the program. Any expenditure that does not meet these criteria may be subject to disallowance or repayment. Condition: During testing of expenditures related to the TRIO program, it was observed that documentation supporting approvals of expenditures and indirect costs was not consistently maintained or approved in accordance with the University ’s internal policy and internal controls. Specifically, invoices and indirect cost calculations were not supported by specific/approved requests and calculations and certain invoices were not formally approved. Cause: The lack of approval and formal calculations appear to stem from inadequate oversight of expense approvals or inconsistent documentation practices. In some cases, personnel responsible for financial management may not have received sufficient training or turnover resulted in a lack of documentation retention noting formal approval. Effect: The University did not have proper internal controls to ensure costs were properly approved in accordance with Uniform Guidance. Questioned Costs: None Repeat Finding: No Recommendations: The University should modify its internal controls to ensure proper approval of federal funds. Implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

As most of the findings were related to turnover and the inability to sufficiently document approvals or processes. Going forward, care should be taken to document necessary approvals in care of the program and academic management. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1161387 2024-004
    Material Weakness Repeat
  • 1161388 2024-005
    Material Weakness Repeat
  • 1161389 2024-006
    Material Weakness Repeat
  • 1161390 2024-007
    Material Weakness Repeat
  • 1161391 2024-008
    Material Weakness Repeat
  • 1161392 2024-009
    Material Weakness Repeat
  • 1161393 2024-011
    Material Weakness Repeat
  • 1161394 2024-004
    Material Weakness Repeat
  • 1161395 2024-008
    Material Weakness Repeat
  • 1161396 2024-011
    Material Weakness Repeat
  • 1161397 2024-004
    Material Weakness Repeat
  • 1161398 2024-008
    Material Weakness Repeat
  • 1161399 2024-011
    Material Weakness Repeat
  • 1161400 2024-010
    Material Weakness Repeat
  • 1161401 2024-004
    Material Weakness Repeat
  • 1161402 2024-008
    Material Weakness Repeat
  • 1161403 2024-011
    Material Weakness Repeat
  • 1161404 2024-004
    Material Weakness Repeat
  • 1161405 2024-008
    Material Weakness Repeat
  • 1161406 2024-011
    Material Weakness Repeat
  • 1161407 2024-004
    Material Weakness Repeat
  • 1161408 2024-005
    Material Weakness Repeat
  • 1161409 2024-006
    Material Weakness Repeat
  • 1161410 2024-008
    Material Weakness Repeat
  • 1161411 2024-009
    Material Weakness Repeat
  • 1161412 2024-011
    Material Weakness Repeat
  • 1161414 2024-003
    Material Weakness Repeat
  • 1161415 2024-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.07M
84.063 FEDERAL PELL GRANT PROGRAM $2.45M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.72M
84.047 TRIO UPWARD BOUND $428,272
84.033 FEDERAL WORK-STUDY PROGRAM $257,699
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $168,199
84.021 OVERSEAS PROGRAMS - GROUP PROJECTS ABROAD $104,391
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $84,387
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $73,919
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $18,680
43.001 SCIENCE $8,473
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $7,260
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $2,386