Finding Text
Information on the federal program: Higher Education Institutional Aid - Hispanic-Serving Institutions – Science, Technology, Engineering, or Mathematics and Articulations Programs (Assistance Listing number 84.031C) and Hispanic-Serving Institutions - (DHSI) Program (Assistance Listing number 84.031S); United States Department of Education; Award Year 2022-23; Internal Control Deficiency; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should follow established procedures to ensure compliance with 2 CFR Part 200 requirements for adequate documentation to support grant expenses.
Condition: Lack of appropriate management review allowed for the following issues in the grant disbursements we tested:
1) Time & effort certifications:
a. One was not completed until after we requested it in the course of the audit.
b. One showed 50% should be charged to the grant, but only 35% was charged to the grant.
c. Two did not list the month on the form.
d. Three showed 80% grant and 20% institutional, but the hours listed showed equal hours for grant and institutional.
e. One was not signed by the supervisor.
f. As noted in 2023-002 above, one showed 35% should be charged to the grant, but 100% was charged to the grant.
2) Five purchases totaling $472,879 did not follow approval procedures outlined in the internal control policy, which required prior Board of Trustee approval for purchases over $17,500.
3) Two purchases totaling $91,975 did not reflect bid approval as outlined in the internal control policy.
Cause: The University implemented a comprehensive system software change during the current year. The additional time required for this effort, coupled with management personnel changes and staff shortages, led to the lack of appropriate approval and review of documentation.
Effect: Incorrect amounts and/or improper payments could be charged to the grant.
Questioned Costs: n/a for this finding.
Context: Our testing included 25 payroll items and 10 payments for goods and services.
Recommendations: Management should add procedures to (1) review payroll charges made to grants each pay period as compared to the time & effort documentation and (2) document approval for purchases and bids, in accordance with policy. If the intent is not for the Board of Trustees to provide approval, policies should be revised to reflect which committee/individuals will provide that approval.
Responsible Official’s Response and Corrective Action Planned: see corrective action plan.