Finding 36455 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2022-11-30
Audit: 28299
Organization: Claremont Graduate University (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University failed to post a required special report on its website within the 30-day deadline after receiving HEERF funds.
  • Impacted Requirements: Compliance with U.S. Department of Education reporting guidelines and 2 CFR 200.303 for maintaining internal controls over federal awards.
  • Recommended Follow-Up: Implement procedures to ensure timely posting of reports and monitor compliance to prevent future delays.

Finding Text

FINDING 2022-001 - Reporting: Significant Deficiency over Internal Controls over Compliance: "See Schedule of Findings and Questioned Costs for chart/table". Criteria: According to an electronic announcement (EA) by U.S. Department of Higher Education (ED) on May 6, 2020, ED required institutions that received a Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely posting of special reports to their website. Condition/Context: The University did not publicly post a special report on a timely basis. The University is required to prepare and publicly post a special report (Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting) with certain information describing the use of funds distributed from the HEERF on their website no later than 30 days after receiving the award. The University was required to publicly post the initial report to its website by January 10, 2022, however, the University first publicly posted the initial report to its website on January 14, 2022. Cause: In discussing these conditions with University management, the delay in publicly posting the special report to the University?s website was due to resource constraints as the University?s information systems personnel were implementing technology to effectively transition to distance learning and remote work in light of the COVID-19 pandemic and related shelter-in-place orders. Effect: Failure to publicly post special reports to the University?s website on a timely basis does not allow the public to access timely information on how the University used the funds received from the HEERF. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University implement procedures to ensure special reports are posted to the University?s website in a timely manner. Views of responsible officials: We agree with the auditor?s comments. These were unprecedented times, and this type of failure is inconsistent with past practice. Reporting requirements are tracked internally via the BlueSky deliverable system. Publishing access to the reporting website has been granted to the Restricted Accounting Supervisor to avoid additional publishing delays.

Categories

Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 36454 2022-001
    Significant Deficiency
  • 612896 2022-001
    Significant Deficiency
  • 612897 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.53M
84.425 Covid-19 Education Stabilization Fund Higher Education Emergency Relief Fund - Institutional Portion $743,707
84.336 Teacher Quality Partnership $496,382
84.425 Covid-19 Education Stabilization Fund Higher Education Emergency Relief Fund - Student Portion $473,506
84.033 Federal Work-Study Program $455,311
47.076 Education and Human Resources $369,241
93.865 Translation of District Sun Safe Policies to Schools $290,390
19.408 Tea Teaching Excellence and Achievement Program $283,675
84.038 Federal Perkins Loan Program (beginning of the Year) $196,827
45.312 The Museum Mentor Network $148,537
93.134 Social and Behavioral Interventions to Increase Solid Organ and Tissue Donation $135,288
93.279 Drug Abuse and Addiction Research Programs $78,460
20.611 Incentive Grant Program to Prohibit Racial Profiling $77,266
84.299 Indian Education -- Special Programs for Indian Children $54,986
93.866 Aging Research $52,583
93.134 Public Education Efforts to Increase Solid Organ Donation $49,166
93.837 Habitual & Neurocogonitive Processes in Adolescent Obesity Prevention $44,296
98.U01 Monitor and Eval Bosnia and Herzeg $42,892
16.560 Violence Agaist Teachers in the 50 Largest U.s. School Districts $40,082
47.075 Social, Behavioral, and Economic Sciences $38,477
45.163 Mormonism and Mexico A Case Study in Religion and Borderlands $33,453
47.049 Mathematical and Physical Sciences $22,024
20.611 Connecticut Racial Profiling Prohibition Project $17,458
93.242 Mental Health Research Grants $16,185
93.243 Substance Abuse and Mental Health Services $12,953
84.379 Teacher Education Assistance for College and Higher Education Grants $7,544
12.800 Dynamics of Common Knowledge on Social Networks $577