Finding 372675 (2023-004)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-06
Audit: 293797
Organization: Berklee College of Music, Inc. (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Key information was missing from the FISAP report, and there was no independent review before submission.
  • Impacted Requirements: Compliance with federal regulations for accurate reporting and internal controls was not met.
  • Recommended Follow-Up: Enhance the preparation and review process for the FISAP to ensure completeness and accuracy before filing.

Finding Text

Criteria ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key Line Items – The following line items contain critical information: Part I, Identifying Information, Certification, and Warning Part II, Application to Participate • Information on enrollment • Assessments and expendituresInformation on eligible aid applicants Part III, Fiscal Operations Report • All sections Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (FSEOG) Program • All sections Part V, Fiscal Operations Report Federal Work-Study (FWS) Program • All sections Part VI, Program Summary for Award Year • Distribution of Program Recipients and Expenditures by Type of Student Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our testwork over the FISAP for the 2022/2023 award year, certain key information as required in Part III, Fiscal Operations Report Section E was omitted. In addition, there was no documentation that the FISAP was reviewed by someone other than the preparer of the report prior to the report being filed with the U.S. Department of Education. Cause The condition resulted from an insufficient review of the report by someone other than the preparer of the report prior to the report being filed with the U.S. Department of Education. Possible Asserted Effect Failure to file accurate and complete information in accordance with federal requirements and implement sufficient internal controls resulted in the College’s FISAP for the 2022/2023 award year being noncompliant with Federal statutes, regulations and the terms and conditions of the awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to the preparation and review of the FISAP to ensure that it is completely and accurately prepared prior to the report being filed with the U.S. Department of Education.

Corrective Action Plan

Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Other Findings in this Audit

  • 372674 2023-003
    Significant Deficiency
  • 372676 2023-005
    Significant Deficiency
  • 372677 2023-006
    Significant Deficiency
  • 949116 2023-003
    Significant Deficiency
  • 949117 2023-004
    Significant Deficiency
  • 949118 2023-005
    Significant Deficiency
  • 949119 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $48.14M
84.063 Federal Pell Grant Program $5.92M
84.425 Education Stabilization Fund $2.08M
84.038 Federal Perkins Student Loans $1.88M
84.007 Federal Supplemental Educational Opportunity Grants $1.32M
84.033 Federal Work-Study Program $435,709
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $389,852