Finding 1205824 (2025-007)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2026-04-02

Audit: 397569

Organization: Dillard University (LA)

Auditor: SEAN M BRUNO CPAS

AI Summary

Core Issue: Twelve out of twenty-five transactions had costs incurred outside the approved period of performance, and one transaction lacked supporting documentation.
Impacted Requirements: Costs must be allowable, properly supported, and incurred during the approved period as per Uniform Guidance §§ 200.403 and 200.309.
Recommended Follow-Up: Strengthen controls to ensure costs are charged within the performance period and implement procedures for retaining adequate documentation for all expenditures.

Finding Text

Allowable Costs/Period of Performance Federal Program and Specific Federal Award Identification CFDA Title and Number 84.031 Higher Education Institution Aid Federal Award Year June 30, 2025 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria In accordance with Uniform Guidance §§ 200.403 and 200.309, costs charged to federal awards must be allowable, properly supported, and incurred during the approved period of performance. Adequate documentation must be maintained to support all expenditures. Conditions and Contexts During my testing, I noted the following: • Out of twenty-five (25) transactions tested, twelve (12) transactions included costs incurred outside the period of performance (before and/or after the fiscal year under audit); and • One (1) of twenty-five (25) transactions selected for testing, supporting documentation was not provided for audit review. Cause The University lacked effective controls to ensure that costs were incurred within the appropriate period of performance and that supporting documentation was retained and made available for audit. Questioned Costs For the purposes of this condition, I have not questioned any costs. Effect Costs may have been improperly charged to the federal program and may be unallowable. Additionally, the lack of supporting documentation limits the ability to determine the allowability and accuracy of expenditures. Repeat Finding No. Recommendation The University should strengthen controls to ensure that only costs incurred within the approved period of performance are charged to federal awards. Additionally, procedures should be implemented to ensure that all expenditures are supported by adequate documentation and are readily available for audit. Management’s Response The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred within the designated performance period, and that proper documentation must be retained for audit purposes. Corrective Actions 1. Improved Period-of-Performance Verification: The University has strengthened its review procedures to ensure all expenses are confirmed as occurring within the applicable grant period before being charged the award. Both grants management and accounting staff now verify dates prior to posting. 2. Enhanced Documentation Requirements: A shared electronic repository is being used to ensure all supporting documents are uploaded and retained before any expenditure is approved. Transactions submitted without documentation are now automatically rejected. 3. Staff Training: Relevant staff have received targeted training on allowable-cost rules, documentation standards, and period-of-performance requirements under Uniform Guidance. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to verify continued compliance and ensure that all costs charged to federal awards are timely, appropriate, and fully supported, and charged within the required time periods. The University believes these actions address the issues noted and will strengthen internal controls over federal expenditures moving forward.

Corrective Action Plan

Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred within the designated performance period, and that proper documentation must be retained for audit purposes. Corrective Actions 1. Improved Period-of-Performance Verification: The University has strengthened its review procedures to ensure all expenses are confirmed as occurring within the applicable grant period before being charged to the award. Both grants management and accounting staff now verify dates prior to posting. 2. Enhanced Documentation Requirements: A shared electronic repository is being used to ensure all supporting documents are uploaded and retained before any expenditure is approved. Transactions submitted without documentation are now automatically rejected. 3. Staff Training: Relevant staff have received targeted training on allowable-cost rules, documentation standards, and period-of-performance requirements under Uniform Guidance. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to verify continued compliance and ensure that all costs charged to federal awards are timely, appropriate, and fully supported, and charged within the required time periods. The University believes these actions address the issues noted and will strengthen internal controls over federal expenditures moving forward.

Other Findings in this Audit

1205818 2025-002

Material Weakness Repeat
1205819 2025-003

Material Weakness Repeat
1205820 2025-004

Material Weakness Repeat
1205821 2025-005

Material Weakness Repeat
1205822 2025-006

Material Weakness Repeat
1205823 2025-011

Material Weakness Repeat
1205825 2025-011

Material Weakness Repeat
1205826 2025-008

Material Weakness Repeat
1205827 2025-009

Material Weakness Repeat
1205828 2025-010

Material Weakness Repeat
1205829 2025-011

Material Weakness Repeat
1205830 2025-011

Material Weakness Repeat
1205831 2025-011

Material Weakness Repeat
1205832 2025-011

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
84.268	FEDERAL DIRECT STUDENT LOANS	$9.87M
84.063	FEDERAL PELL GRANT PROGRAM	$4.97M
84.031	HIGHER EDUCATION INSTITUTIONAL AID	$4.05M
12.630	BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING	$522,396
84.044	TRIO TALENT SEARCH	$429,672
84.033	FEDERAL WORK-STUDY PROGRAM	$286,248
84.007	FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS	$280,908
84.042	TRIO STUDENT SUPPORT SERVICES	$257,304
12.800	AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM	$251,032
84.217	TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT	$238,039
93.859	BIOMEDICAL RESEARCH AND RESEARCH TRAINING	$197,089
84.120	MINORITY SCIECE AND ENGINEERING INPROVEMENT	$191,930
81.049	OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM	$189,415
93.364	NURSING STUDENT LOANS	$118,577
47.075	SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES	$108,941
84.184	SCHOOL SAFELY NATIONAL ACTIVITIES	$104,784
94.066	AMERICORPS STATE AND NATIONAL	$98,128
47.050	GEOSCIENCES	$79,010
15.941	MISSISSIPPI NATIONAL RIVER AND RECREATION AREA STATE AND LOCAL ASSISTANCE	$73,366
93.865	CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH	$60,063
47.076	STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES)	$53,142
66.616	ENVIRONMENTAL AND CLIMATE JUSTICE COMMUNITY CHANGE GRANTS PROGRAM	$50,000
47.083	INTEGRATIVE ACTIVITIES	$46,106
15.932	PRESERVATION OF HISTORIC STRUCTURES ON THE CAMPUSES OF HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCUS).	$36,611
93.307	MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH	$27,632
16.525	GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS	$22,569
84.425	EDUCATION STABILIZATION FUND	$18,875
10.217	HIGHER EDUCATION - INSTITUTION CHALLENGE GRANTS PROGRAM	$16,576
47.070	COMPUTER AND INFORMATION SCIENCE AND ENGINEERING	$12,459
45.162	PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT	$12,223
93.145	HIV-RELATED TRAINING AND TECHNICAL ASSISTANCE	$6,900
93.421	STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATIONÂS HEALTH	$6,767
11.307	ECONOMIC ADJUSTMENT ASSISTANCE	$4,626
97.132	FINANCIAL ASSISTANCE FOR TARGETED VIOLENCE AND TERRORISM PREVENTION	$4,229
12.902	INFORMATION SECURITY GRANTS	$93
93.391	ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES	$-714
93.368	21ST CENTURY CURES ACT - PRECISION MEDICINE INITIATIVE	$-717