Finding 1240493 (2025-008)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-10-15
Audit: 414959
Organization: Heritage University (WA)

AI Summary

  • Core Issue: There are significant weaknesses in internal controls over compliance related to employee compensation charged to federal awards, with errors found in 5 out of 6 sampled employees.
  • Impacted Requirements: Compensation costs must meet 2 CFR section 200.430 standards, including accurate time and effort reporting, which was not adhered to in multiple instances.
  • Recommended Follow-Up: The University should establish a robust internal control policy to ensure compliance with 2 CFR section 200.430(g) and improve accuracy in time and effort reporting.

Finding Text

2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance National Science Foundation Federal Assistance Listing Number: Various Federal Program Name: Research and Development Cluster Federal Award Number: Various Award Year: 2024-25, 2023-24 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(g), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 6 employees out of a population of 15 employees whose compensation was charged to the awards was selected. Of the 6 employees selected we found errors with 5 employees, across a sample of 12 separate payroll transactions, which consisted of the following: • For 2 employees across one or more payroll transactions selected, no records were available to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. • For 3 employees across one or more payroll transactions selected, the time and effort reports were missing key elements including employee signatures and indication of timely review by an individual knowledgeable of grant activities. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable as records to support allocation were not complete or accurate. Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2024-009 Recommendation – We recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects.

Corrective Action Plan

8. 2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1240464 2025-002
    Material Weakness Repeat
  • 1240465 2025-002
    Material Weakness Repeat
  • 1240466 2025-003
    Material Weakness Repeat
  • 1240467 2025-003
    Material Weakness Repeat
  • 1240468 2025-004
    Material Weakness Repeat
  • 1240469 2025-004
    Material Weakness Repeat
  • 1240470 2025-004
    Material Weakness Repeat
  • 1240471 2025-004
    Material Weakness Repeat
  • 1240472 2025-004
    Material Weakness Repeat
  • 1240473 2025-004
    Material Weakness Repeat
  • 1240474 2025-004
    Material Weakness Repeat
  • 1240475 2025-004
    Material Weakness Repeat
  • 1240476 2025-004
    Material Weakness Repeat
  • 1240477 2025-004
    Material Weakness Repeat
  • 1240478 2025-005
    Material Weakness Repeat
  • 1240479 2025-005
    Material Weakness Repeat
  • 1240480 2025-005
    Material Weakness Repeat
  • 1240481 2025-006
    Material Weakness Repeat
  • 1240482 2025-006
    Material Weakness Repeat
  • 1240483 2025-006
    Material Weakness Repeat
  • 1240484 2025-006
    Material Weakness Repeat
  • 1240485 2025-007
    Material Weakness Repeat
  • 1240486 2025-007
    Material Weakness Repeat
  • 1240487 2025-008
    Material Weakness Repeat
  • 1240488 2025-008
    Material Weakness Repeat
  • 1240489 2025-008
    Material Weakness Repeat
  • 1240490 2025-008
    Material Weakness Repeat
  • 1240491 2025-008
    Material Weakness Repeat
  • 1240492 2025-008
    Material Weakness Repeat
  • 1240494 2025-009
    Material Weakness Repeat
  • 1240495 2025-009
    Material Weakness Repeat
  • 1240496 2025-010
    Material Weakness Repeat
  • 1240497 2025-010
    Material Weakness Repeat
  • 1240498 2025-011
    Material Weakness Repeat
  • 1240499 2025-011
    Material Weakness Repeat
  • 1240500 2025-011
    Material Weakness Repeat
  • 1240501 2025-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $3.79M
84.268 FEDERAL DIRECT STUDENT LOANS $3.25M
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $1.32M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $535,630
84.031 HIGHER EDUCATION INSTITUTIONAL AID $495,537
84.141 MIGRANT EDUCATION HIGH SCHOOL EQUIVALENCY PROGRAM $494,528
84.149 MIGRANT EDUCATION COLLEGE ASSISTANCE MIGRANT PROGRAM $453,194
84.042 TRIO STUDENT SUPPORT SERVICES $263,859
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $218,194
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $104,462
84.033 FEDERAL WORK-STUDY PROGRAM $90,480
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $48,248
10.558 CHILD AND ADULT CARE FOOD PROGRAM $33,141
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $30,407
43.001 SCIENCE $13,280
47.074 BIOLOGICAL SCIENCES $7,041