Finding 1167860 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-01-06
Audit: 379231
Organization: Northern Michigan University (MI)

AI Summary

  • Core Issue: The University lacks formal review procedures for federal grant drawdowns, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR §200.305(b) regarding timely fund disbursement and documentation of allowable expenditures.
  • Recommended Follow-Up: Establish documented review procedures, designate reviewers, and implement system controls for accurate and allowable drawdowns.

Finding Text

Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Cash Management). Program. Research and Development Cluster; all Assistance Listing Numbers; all Award Numbers. Criteria. Per 2 CFR §200.305(b), non-federal entities must minimize the time elapsing between the transfer of funds and disbursement. Entities must also ensure that drawdowns are based on actual, allowable expenditures and supported by adequate documentation. Condition. The University did not have documented review procedures in place for federal grant drawdowns under the Research and Development cluster. Drawdowns were processed without a formal review or approval process to verify that amounts requested were based on allowable expenditures. Cause. The University lacked formal internal controls and oversight mechanisms to ensure drawdowns were reviewed prior to submission. The process relied on informal practices without documented policies or designated reviewers. Effect. This deficiency increases the risk of drawing federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Questioned Costs. No costs were questioned related to this finding. Recommendation. The University should implement formal review procedures for all federal grant drawdowns, including documented policies, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following is the finding as noted in the Northern Michigan University Single Audit Act Compliance report for the year ended June 30, 2025, and corrective action to be completed. 2025-001 – Lack of Drawdown Review Procedures Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns under the Research and Development cluster. Drawdowns were processed without a formal review or approval process to verify that amounts requested were based on allowable expenditures. This deficiency increases the risk of drawing federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Auditor Recommendation. The University should implement formal review procedures for all federal grant drawdowns, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. Corrective Action. The University is developing formal grant drawdown review procedures that outlines required documentation and review steps around federal grant drawdowns. Responsible Person. Jamie Beauchamp, Controller Anticipated Completion Date. January 31, 2026.

Categories

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1167852 2025-001
    Material Weakness Repeat
  • 1167853 2025-001
    Material Weakness Repeat
  • 1167854 2025-001
    Material Weakness Repeat
  • 1167855 2025-001
    Material Weakness Repeat
  • 1167856 2025-001
    Material Weakness Repeat
  • 1167857 2025-001
    Material Weakness Repeat
  • 1167858 2025-001
    Material Weakness Repeat
  • 1167859 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $27.84M
84.063 FEDERAL PELL GRANT PROGRAM $13.39M
32.010 SUPPLY CHAIN REIMBURSEMENT PROGRAM $3.33M
84.038 FEDERAL PERKINS LOAN $1.17M
84.033 FEDERAL WORK-STUDY PROGRAM $877,740
93.279 DRUG ABUSE AND ADDICTION RESEARCH PROGRAMS $772,039
84.042 TRIO_STUDENT SUPPORT SERVICES $431,406
84.047 TRIO_UPWARD BOUND $368,281
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $291,682
84.217 TRIO_MCNAIR POST-BACCALAUREATE ACHIEVEMENT $270,321
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $247,625
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $195,089
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS Ð RESOURCES OF THE NATIONAL PARK SYSTEM $160,352
16.841 VOCA TRIBAL VICTIM SERVICES SET-ASIDE PROGRAM $145,378
15.114 INDIAN EDUCATION_HIGHER EDUCATION GRANT PROGRAM $133,730
47.076 EDUCATION AND HUMAN RESOURCES $108,938
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $93,207
93.247 ADVANCED NURSING EDUCATION GRANT PROGRAM $90,441
45.161 PROMOTION OF THE HUMANITIES_RESEARCH $72,069
97.127 CYBERSECURITY EDUCATION AND TRAINING ASSISTANCE PROGRAM (CETAP) $68,982
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $62,227
47.050 GEOSCIENCES $58,541
93.110 MATERNAL AND CHILD HEALTH FEDERAL CONSOLIDATED PROGRAMS $35,478
45.310 GRANTS TO STATES $24,982
10.755 RURAL INNOVATION STRONGER ECONOMY $24,318
47.074 BIOLOGICAL SCIENCES $22,385
19.009 ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS $16,840
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $16,039
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $12,551
45.025 PROMOTION OF THE ARTS_PARTNERSHIP AGREEMENTS $12,000
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,316
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $9,249
16.560 NATIONAL INSTITUTE OF JUSTICE RESEARCH, EVALUATION, AND DEVELOPMENT PROJECT GRANTS $7,190
17.259 WIA YOUTH ACTIVITIES $5,784
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $5,000
93.912 RURAL HEALTH CARE SERVICES OUTREACH, RURAL HEALTH NETWORK DEVELOPMENT AND SMALL HEALTH CARE PROVIDER QUALITY IMPROVEMENT $3,000
45.129 PROMOTION OF THE HUMANITIES_FEDERAL/STATE PARTNERSHIP $1,052