Finding 1240243 (2025-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-10-10

AI Summary

  • Core Issue: The auditee failed to submit the Single Audit Reporting Package to the Federal Audit Clearinghouse on time, violating 2 CFR § 200.512(a).
  • Impacted Requirements: Timely submission is crucial for compliance with Uniform Guidance, affecting the auditee's low-risk status under 2 CFR § 200.520.
  • Recommended Follow-Up: Implement formal procedures to monitor deadlines, designate personnel for tracking submissions, and ensure proactive communication with oversight agencies regarding potential delays.

Finding Text

Finding 2025-003 – Untimely Submission of the Single Audit Reporting Package to the Federal Audit Clearinghouse (FAC) (Material Weakness): Information on the federal program – Applicable to all federal programs subject to the Uniform Guidance audit requirements because the reporting package and data collection form submission requirements apply to the auditee’s Uniform Guidance reporting package. Criteria – Section 2 CFR §200.512(a) of the Uniform Guidance requires that “the reporting package and the Data Collection Form (DCF) must be electronically submitted by the auditee to the FAC” and that “submission must be completed within 30 calendar days after the auditee receives the auditor’s reports or 9 months after the end of the audit period, whichever is earlier.” Section 2 CFR §200.520 of the Uniform Guidance provides that one of the conditions necessary to qualify as a low-risk auditee is that “the prior 2 years’ audits must have been performed on an annual basis in accordance with the Uniform Guidance, including report submission to the FAC by the due date.” The Uniform Guidance also states that if an auditee expects a late submission, “the suggested way to do so is to contact the federal oversight or cognizant agency for the audit.” Condition – The auditee did not submit its audit reporting package and data collection form to the Federal Audit Clearinghouse within the time frame required by 2 CFR § 200.512(a). Specifically, the 2024 audit reporting package was submitted more than one year after the required due date, the 2023 reporting package was submitted 11 days late, and as of August 2026 the 2025 reporting package has not yet been submitted and is expected to be late. Cause – Based on discussions with management and auditor procedures performed, the auditee did not maintain an effective process to monitor Uniform Guidance reporting deadlines and ensure timely completion and submission of the reporting package and data collection form to the FAC. Effect – Failure to submit the reporting package and data collection form within the required deadline constitutes noncompliance with 2 CFR § 200.512(a). Repeated late submissions may affect the auditee’s ability to qualify as a low-risk auditee because timely FAC submission is one of the required conditions under Section 2 CFR § 200.520 of the Uniform Guidance. Questioned Costs – N/A Repeat Finding – No. However late FAC submissions occurred in prior reporting periods. Auditor’s Perspective – From the auditor’s perspective, repeated late submissions over multiple audit periods indicate a pattern of noncompliance with Uniform Guidance reporting requirements and suggest deficiencies in the auditee’s monitoring controls over regulatory reporting deadlines. The auditor also noted that the Uniform Guidance permits communication with the cognizant or oversight agency when a submission will be late; however, no evidence was provided that such communication occurred for all affected periods reviewed. Auditor's Recommendation – We recommend management implement formal procedures and monitoring controls to ensure completion and electronic submission of the reporting package and data collection form within the deadline established by 2 CFR § 200.512(a). We also recommend management designate responsible personnel to track Uniform Guidance due dates, maintain submission documentation, and communicate proactively with the cognizant or oversight agency if delays are anticipated. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.

Corrective Action Plan

Institution Name Philander Smith University Fiscal Year Ended June 30, 2025 Federal Program / Assistance Listing Number (ALN) Finding Reference Number 2025-003 1. Finding Summary The auditor noted that the University did not submit is audit reporting package and data collection form to the Federal Audit Clearinghouse within the time frame required. 2. Management’s Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the identified condition resulted from staffing vacancies and timing delays in the annual audit caused by limited staff. 3. Root Cause Analysis The root cause was staffing vacancies which has caused the University to fall behind on key reconciliations and month-end close processes. With fewer personnel, existing staff had to take on additional responsibilities which has caused slower turnaround times for day-to-day duties. Although staff are cross-trained where appropriate, vacancies disrupt normal workflows. 4. Corrective Action(s) Management is working to fill vacancies and also further cross-train staff. The University is also considering how to best engage temporary staff based on funding available from vacancies. The University acknowledges that although month-end workflows are in place, monitoring needs to be strengthen, especially during peak times. Finally, the University is investing in a new cloud-based Enterprise Resource Planning (ERP) software designed for higher education institutions, Ellucian Colleague, which should automate more business processes and reconciliations. Description of Corrective Actions The University has recently hired a Controller, a position which has been vacant for some time. The Controller will work to strengthen month-end workflows, staff training, and to fill remaining vacancies. 5. Risk Mitigation (Required — Even if Disagreeing) The University institution recognizes the importance of mitigating compliance risk in this area. Accordingly, the corrective actions described above are designed to reduce the risk of inconsistent documentation, misinterpretation of regulatory requirements, and future audit findings. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Vice President for Fiscal Affairs • Name (optional): _____________________________ 7. Implementation Timeline • Corrective action implemented: ☒ Yes ☐ No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ☐ Fully implemented ☐ Partially implemented ☐ Not yet implemented Evidence of Implementation Hiring documentation for the Controller. 9. Monitoring and Sustainability The University will conduct quarterly internal reviews of month-end close commencing the period ending June 30, 2026 to monitor progress with audit preparation which will ensure timely Federal Audit Clearinghouse submission. 10. Management Certification I certify that the information provided above is accurate and represents management’s corrective action plan for the audit finding identified. Signature: ________________________________________________ Name: __LaTonya Hayes_____________________________________ Title: ___Interim CFO_______________________________________ Email: __lhayes@philander.edu_______________________________ Phone: __(501) 370-5341____________________________________ Date: ___9/17/2026__________________________________________

Categories

Reporting Subrecipient Monitoring Material Weakness

Other Findings in this Audit

  • 1240228 2025-003
    Material Weakness Repeat
  • 1240229 2025-003
    Material Weakness Repeat
  • 1240230 2025-003
    Material Weakness Repeat
  • 1240231 2025-003
    Material Weakness Repeat
  • 1240232 2025-003
    Material Weakness Repeat
  • 1240233 2025-003
    Material Weakness Repeat
  • 1240234 2025-003
    Material Weakness Repeat
  • 1240235 2025-003
    Material Weakness Repeat
  • 1240236 2025-003
    Material Weakness Repeat
  • 1240237 2025-003
    Material Weakness Repeat
  • 1240238 2025-003
    Material Weakness Repeat
  • 1240239 2025-003
    Material Weakness Repeat
  • 1240240 2025-003
    Material Weakness Repeat
  • 1240241 2025-003
    Material Weakness Repeat
  • 1240242 2025-003
    Material Weakness Repeat
  • 1240244 2025-004
    Material Weakness Repeat
  • 1240245 2025-005
    Material Weakness Repeat
  • 1240246 2025-006
    Material Weakness Repeat
  • 1240247 2025-006
    Material Weakness Repeat
  • 1240248 2025-006
    Material Weakness Repeat
  • 1240249 2025-006
    Material Weakness Repeat
  • 1240250 2025-007
    Material Weakness Repeat
  • 1240251 2025-007
    Material Weakness Repeat
  • 1240252 2025-007
    Material Weakness Repeat
  • 1240253 2025-007
    Material Weakness Repeat
  • 1240254 2025-008
    Material Weakness Repeat
  • 1240255 2025-008
    Material Weakness Repeat
  • 1240256 2025-008
    Material Weakness Repeat
  • 1240257 2025-008
    Material Weakness Repeat
  • 1240258 2025-009
    Material Weakness Repeat
  • 1240259 2025-009
    Material Weakness Repeat
  • 1240260 2025-009
    Material Weakness Repeat
  • 1240261 2025-009
    Material Weakness Repeat
  • 1240262 2025-010
    Material Weakness Repeat
  • 1240263 2025-010
    Material Weakness Repeat
  • 1240264 2025-010
    Material Weakness Repeat
  • 1240265 2025-010
    Material Weakness Repeat
  • 1240266 2025-011
    Material Weakness Repeat
  • 1240267 2025-011
    Material Weakness Repeat
  • 1240268 2025-011
    Material Weakness Repeat
  • 1240269 2025-011
    Material Weakness Repeat
  • 1240270 2025-012
    Material Weakness Repeat
  • 1240271 2025-012
    Material Weakness Repeat
  • 1240272 2025-012
    Material Weakness Repeat
  • 1240273 2025-012
    Material Weakness Repeat
  • 1240274 2025-013
    Material Weakness Repeat
  • 1240275 2025-013
    Material Weakness Repeat
  • 1240276 2025-013
    Material Weakness Repeat
  • 1240277 2025-013
    Material Weakness Repeat
  • 1240278 2025-014
    Material Weakness Repeat
  • 1240279 2025-014
    Material Weakness Repeat
  • 1240280 2025-014
    Material Weakness Repeat
  • 1240281 2025-014
    Material Weakness Repeat
  • 1240282 2025-015
    Material Weakness Repeat
  • 1240283 2025-015
    Material Weakness Repeat
  • 1240284 2025-015
    Material Weakness Repeat
  • 1240285 2025-015
    Material Weakness Repeat
  • 1240286 2025-016
    Material Weakness Repeat
  • 1240287 2025-016
    Material Weakness Repeat
  • 1240288 2025-016
    Material Weakness Repeat
  • 1240289 2025-016
    Material Weakness Repeat
  • 1240290 2025-017
    Material Weakness Repeat
  • 1240291 2025-017
    Material Weakness Repeat
  • 1240292 2025-017
    Material Weakness Repeat
  • 1240293 2025-017
    Material Weakness Repeat
  • 1240294 2025-018
    Material Weakness Repeat
  • 1240295 2025-018
    Material Weakness Repeat
  • 1240296 2025-018
    Material Weakness Repeat
  • 1240297 2025-018
    Material Weakness Repeat
  • 1240298 2025-019
    Material Weakness Repeat
  • 1240299 2025-019
    Material Weakness Repeat
  • 1240300 2025-019
    Material Weakness Repeat
  • 1240301 2025-019
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.67M
84.063 FEDERAL PELL GRANT PROGRAM $3.57M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $566,939
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $445,997
93.658 FOSTER CARE_TITLE IV-E $212,366
84.033 FEDERAL WORK-STUDY PROGRAM $88,615
47.076 EDUCATION AND HUMAN RESOURCES $65,481
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $37,012
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $14,994
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $11,071
47.083 INTEGRATIVE ACTIVITIES $4,382