Finding 1164304 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-10
Audit: 373716
Organization: Rivier University (NH)

AI Summary

  • Core Issue: The University did not verify employees against the System for Award Management (SAM) for transactions over $25,000, risking compliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR, Part 200 mandates verification of vendors and employees in covered transactions to prevent funding to suspended or debarred individuals.
  • Recommended Follow-Up: Implement and document the established process for checking SAM to ensure all relevant employees are verified before disbursing federal funds.

Finding Text

Information on the Federal Program: Federal Agency: United States Department of Health and Human Services Program Name: Nurse Education, Practice, Quality and Retention Assistance Listing Number: 93.359 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2025 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, the institution must verify that the vendor and/or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted that management did not review the SAM for employees meeting the covered transaction threshold. Context: We noted there were three employees exceeding $25,000 funded by the program. Based on our testing, none of the employees exceeding the $25,000 limit were included in the SAM and received payments funded by the University’s major programs. Questioned Costs: None. Cause and Effect: The University was aware of the requirement to verify vendors and employees and they have a process established as part of their year-end close, but the review was not completed. Since this process was not performed, there is a greater risk of vendors and employees that are included on the SAM being disbursed funds through federal funds. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the University follow established procedures for comparing vendors and employees against the SAM and maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan on page 44.

Corrective Action Plan

The Controller will revise current processes to include documented review of employees against SAM prior to expending against federal awards. Updated procedures will be documented and Controller’s office staff will be trained on the new procedures. Responsible Party: Steven Perrotta Vice President for Finance and Administration Phone: (603) 897-8501 Anticipated Completion Date: December 31, 2025

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $14.11M
93.493 CONGRESSIONAL DIRECTIVES $2.18M
84.063 FEDERAL PELL GRANT PROGRAM $2.13M
93.359 NURSE EDUCATION, PRACTICE QUALITY AND RETENTION GRANTS $1.24M
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $385,460
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $288,046
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $144,090
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $91,395
93.389 NATIONAL CENTER FOR RESEARCH RESOURCES $69,093
84.033 FEDERAL WORK-STUDY PROGRAM $63,982
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $6,593