Finding 1176579 (2025-010)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-05
Audit: 390365
Organization: Johnson C. Smith University (NC)
Auditor: BDO USA PC

AI Summary

  • Core Issue: The University failed to provide necessary documentation for key items in semi-annual CMC and annual TRIO reports, leading to non-compliance with federal reporting requirements.
  • Impacted Requirements: Reports must be submitted within 30 days after the reporting periods, with critical information reconciled to institutional records.
  • Recommended Follow-Up: Enhance internal controls and establish formal policies to ensure compliance with reporting requirements and proper documentation retention.

Finding Text

Federal Program Information: Connecting Minority Communities Pilot Program (11.028) and TRIO Cluster (84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Under the CMC grant program, grantees must submit semi-annual Federal Financial and performance reports for the periods ending March 31 and September 30 of each year. Reports are due within 30 days after the end of the reporting period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Grantees under the TRIO program must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University was unable to provide documentation supporting certain other key items containing critical information included within semi-annual CMC reports and annual TRIO reports. Cause: Insufficient administrative oversight and internal controls over CMC program and TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with the respective CMC program and TRIO program reporting requirements. Questioned Costs: None. Context: We noted the following exceptions during our testing: • For 1 of 2 reports selected for testing in the CMC program, certain key line items contained errors in the information reported. • For 1 of 1 reports selected for testing in the TRIO McNair program, certain key line items contained errors in the information reported. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2024-012 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 required reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required. Views of Responsible Officials: The TRIO Programs (Upward Bound, Student Support Services and McNair) 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 TRIO Programs, we encountered difficulty locating documentation for students who were awarded grant aid as well as official appointment and start dates. During the Spring of 2025 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, 2025.

Corrective Action Plan

Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and programregulations. The University continues to enhance its internal controls, policies and procedures toensure the appropriate documentation to support is maintained. Primary Control Enhancements. During the next Annual Performance Report (APR) reporting cycle, the AVP for Student Affairs, TRIO and Well-being as well as the respective TRIO program director will correct the inaccurately reported Project Entry Date and First Date of Postsecondary Enrollment for affected participants. These data elements are editable within the APR system and will be updated to align with official institutional and program records. Supporting Controls and Training. To support ongoing compliance, the Federal TRIO Programs have strengthened internal controls and will continue to conduct annual reviews of policies, procedures, and internal controls to ensure alignment with federal regulations and grant administration best practices. To ensure consistent implementation, monthly staff trainings are conducted using the TRIO General Guidelines. In addition, TRIO staff will continue to participate in local and national professional development opportunities to enhance grant management knowledge and standardize practices related to program administration and federal reporting. To ensure all APR reports are accurate moving forward, all APR reports will be completed prior to the deadline and the TRIO staff along with GSPAR will review for accuracy and completeness. Monitoring and Quality Assurance. To further strengthen compliance efforts, the AVP for Student Affairs, TRIO, and Well-being developed a comprehensive TRIO General Guidelines resource for program personnel. The TRIO General Guidelines will be updated to include new JCSU policies that relate to TRIO program management. Informed by Johnson C. Smith University institutional policies, federal TRIO regulations, and best practices from peer institutions, the guide addresses grant administration, record-keeping, participant eligibility, program services, fiscal management, personnel, and travel. TRIO personnel, in collaboration with the Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being, will continue to conduct regular reviews of participant files and program records to verify data accuracy and regulatory compliance prior to federal reporting. Sustained Oversight. The university will engage in continuous monitoring and evaluation to assess the effectiveness of these corrective actions, identify opportunities for improvement, and maintain full compliance with all applicable regulatory requirements. Anticipated Completion Date: June 2026

Categories

Internal Control / Segregation of Duties Period of Performance Reporting

Other Findings in this Audit

  • 1176550 2025-001
    Material Weakness Repeat
  • 1176551 2025-001
    Material Weakness Repeat
  • 1176552 2025-001
    Material Weakness Repeat
  • 1176553 2025-001
    Material Weakness Repeat
  • 1176554 2025-002
    Material Weakness Repeat
  • 1176555 2025-002
    Material Weakness Repeat
  • 1176556 2025-003
    Material Weakness Repeat
  • 1176557 2025-003
    Material Weakness Repeat
  • 1176558 2025-003
    Material Weakness Repeat
  • 1176559 2025-003
    Material Weakness Repeat
  • 1176560 2025-004
    Material Weakness Repeat
  • 1176561 2025-005
    Material Weakness Repeat
  • 1176562 2025-005
    Material Weakness Repeat
  • 1176563 2025-005
    Material Weakness Repeat
  • 1176564 2025-006
    Material Weakness Repeat
  • 1176565 2025-006
    Material Weakness Repeat
  • 1176566 2025-006
    Material Weakness Repeat
  • 1176567 2025-007
    Material Weakness Repeat
  • 1176568 2025-007
    Material Weakness Repeat
  • 1176569 2025-008
    Material Weakness Repeat
  • 1176570 2025-008
    Material Weakness Repeat
  • 1176571 2025-008
    Material Weakness Repeat
  • 1176572 2025-008
    Material Weakness Repeat
  • 1176573 2025-008
    Material Weakness Repeat
  • 1176574 2025-008
    Material Weakness Repeat
  • 1176575 2025-009
    Material Weakness Repeat
  • 1176576 2025-009
    Material Weakness Repeat
  • 1176577 2025-009
    Material Weakness Repeat
  • 1176578 2025-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $12.35M
84.063 FEDERAL PELL GRANT PROGRAM $6.16M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $2.38M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $499,663
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $457,333
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $401,852
84.033 FEDERAL WORK-STUDY PROGRAM $388,738
84.047 TRIO UPWARD BOUND $369,588
84.042 TRIO STUDENT SUPPORT SERVICES $366,285
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $269,267
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $232,533
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $201,323
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $185,839
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $48,474
89.003 NATIONAL HISTORICAL PUBLICATIONS AND RECORDS GRANTS $46,856
97.062 SCIENTIFIC LEADERSHIP AWARDS $26,250
97.061 CENTERS FOR HOMELAND SECURITY $15,207
11.417 SEA GRANT SUPPORT $5,250
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $4,800
93.310 TRANS-NIH RESEARCH SUPPORT $2,000
17.268 H-1B JOB TRAINING GRANTS $1,078
54.001 INTELLIGENCE COMMUNITY CENTERS FOR ACADEMIC EXCELLENCE $773