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FINDING 2025-001 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Federal Appropriations Assistance Listing Number: 84.910A Criteria: Pursuant to the Education of the Deaf Act, 20 U.S.C. § 4354(2), Gallaudet University is required to prepare and submit an Annual Report of Achievements (“Annual Report”) containing specified information regarding educational, recruitment, and employment activities. The required information includes: (1) the number of recruitment activities by type and location for all educational levels under 20 U.S.C. § 4354(2)(E), and (2) employment openings/vacancies by grade level or job type and the number of individuals who applied and were hired under 20 U.S.C. § 4354(2)(F). The University is responsible for maintaining sufficient records to support the completeness and accuracy of information reported in the Annual Report. Condition: The University reported the recruitment and employment information required under the Education of the Deaf Act in its Annual Report; however, it did not retain sufficient supporting documentation to substantiate the reported disclosures. Specifically, the University was unable to provide the underlying source data supporting: (1) the number of recruitment activities by type and location for all educational levels and (2) employment openings and vacancies, grade level or type of job, and the number of individuals who applied and were hired. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included in the Annual Report, and the audit team was unable to verify the reported metrics/data. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the Annual Report increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the reporting requirements of the Education of the Deaf Act. Context: During testing of the University's Annual Report, required under the Education of the Deaf Act, the audit team tested all tables and disclosures subject to the reporting requirements. The exceptions identified affected two required reporting elements: (1) recruitment activities by type and location for all educational levels and, (2) employment openings/vacancies, grade level or job type, and applicant and hiring statistics. No supporting documentation was available to support the data presented for either disclosure. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the Annual Report. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for Annual Report disclosures required under the Education of the Deaf Act. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported metrics/data. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.