Federal Program Department of Education - Strengthening Institutions Program, ALN 84.031A, Award No. P031A190172, Period 10/1/19 - 9/30/24 Condition/Cause During the year ended June 30, 2022, an individual working in an allowable position under the grant changed job titles to a different position, which was not allowable under the grant. The wages and fringe benefits for this individual continued to be charged to the grant after the change in position. Internal controls in place did not detect the unallowable costs charged to the grant in the 4th quarter of the fiscal year, prior to drawing down funds. Recommendation We recommend that the University revisit and strengthen internal controls over determining compliance with the allowable activities and allowable cost requirements of the grant for wages and fringe benefits. Management Response We agree with the auditors' finding. The instance of non-compliance occurred during a period when the University had a vacancy in the Grant Specialist position. This role?s duty includes oversight of the internal control environment regarding the compliance of the federal program. Effective August 2022, the position has been filled and corrective actions are in process to strengthen internal controls to avoid non-compliance going forward. To mitigate deficiencies in controls regarding change management, personnel status change forms involving federally funded programs will be circulated to the Program Director, Grant Specialist, and Business Affairs office. In addition, the Program Director will reconcile funds disbursed for unallowable costs prior to the filing of the September 30, 2023 annual report.