Finding 1227459 (2025-007)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-08-20
Audit: 409492
Organization: The Institute of World Politics (DC)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The Institute failed to submit the 2024 Data Collection Form (DCF) on time, violating federal reporting requirements.
  • Impacted Requirements: Noncompliance with 2 CFR § 200.512 and Uniform Guidance, risking increased scrutiny from federal agencies.
  • Recommended Follow-Up: Strengthen controls by assigning clear responsibilities and implementing documented review procedures to ensure timely submissions.

Finding Text

Finding 2025-007: 2024 Data Collection Form (DCF) Late Filing Material Weakness and Other Matter Noncompliance Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: August 1, 2024–July 31, 2025 Criteria: In accordance with 2 CFR § 200.512, the auditee is required to electronically submit the DCF and reporting package to the Federal Audit Clearinghouse (FAC). Additionally, Uniform Guidance requires the reporting package to be submitted the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period. Condition: The Institute did not submit the fiscal year 2024 DCF and related reporting package to the Federal Audit Clearinghouse within the required time frame. Cause: The delay in submission was due to inadequate processes and controls to ensure timely completion, review, and certification of the DCF and reporting package prior to the filing deadline. Effect: Failure to submit the DCF within the required time frame results in noncompliance with federal reporting requirements, which may impact federal oversight and could subject the auditee to increased scrutiny from federal agencies or pass-through entities. Repeat finding: No. Questioned costs: None. Context: Based on review of the submission records, the reporting package, including the DCF, was submitted after the required deadline, resulting in noncompliance with Uniform Guidance reporting requirements. Recommendation: We recommend that management strengthen the control environment over Uniform Guidance compliance by establishing clear accountability for the timely completion of audit requests, preparation and review of the reporting package, and submission of the DCF. Formalized responsibilities, documented review procedures, and management oversight should be implemented to ensure compliance requirements are completed accurately and within required deadlines. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Uniform Guidance reporting requirements: 1. Establish Formal Single Audit Reporting Procedures • The Institute will develop and maintain written procedures governing the annual Single Audit reporting process, including the preparation, review, approval, and submission of the Data Collection Form and reporting package. Procedures will clearly identify filing deadlines, responsible personnel, required approvals, and submission requirements. 2. Assign Responsibility and Accountability • Management will formally designate responsibility for coordinating the annual audit reporting process, including monitoring auditor requests, gathering required documentation, preparing the Data Collection Form, obtaining management approvals, and ensuring timely submission to the Federal Audit Clearinghouse. 3. Implement an Audit and Compliance Calendar • The Institute will establish a compliance calendar that includes all critical audit and federal reporting deadlines. Key milestones will include audit preparation activities, auditor request completion, draft financial statement review, issuance of the auditor's reports, Data Collection Form preparation, management certification, and FAC submission deadlines. 4. Strengthen Management Review Controls • Management will implement documented review procedures for the reporting package and Data Collection Form prior to submission. Review controls will verify the accuracy, completeness, and timeliness of information reported and ensure compliance with Uniform Guidance requirements. 5. Monitor Audit Requests and Submission Readiness • A tracking mechanism will be implemented to monitor the status of auditor requests, outstanding items, and reporting package preparation throughout the audit process. Periodic status meetings will be conducted to identify potential delays and ensure timely resolution of open items. 6. Maintain Evidence of Filing and Review • The Institute will retain documentation supporting preparation, review, approval, and submission of the Data Collection Form and reporting package, including filing confirmations, management approvals, submission receipts, and related correspondence. 7. Ongoing Oversight and Compliance Monitoring • Senior management will periodically review compliance with federal reporting deadlines and monitor the effectiveness of implemented controls. Any compliance issues identified will be evaluated and addressed promptly to prevent future late filings. Responsible Officials: • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr. Thelbert Snowden Anticipated completion date: The Institute will implement formal reporting procedures, deadline tracking tools, management review controls, and accountability measures by December 31, 2026. These procedures will be incorporated into all future Single Audit reporting cycles.

Categories

Internal Control / Segregation of Duties Material Weakness Reporting

Other Findings in this Audit

  • 1227454 2025-002
    Material Weakness Repeat
  • 1227455 2025-003
    Material Weakness Repeat
  • 1227456 2025-004
    Material Weakness Repeat
  • 1227457 2025-005
    Material Weakness Repeat
  • 1227458 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $1.20M