Finding 395176 (2023-002)

-
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-04-30
Audit: 305066
Organization: The Shaw University, Inc. (NC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University exceeded the allowable 10% carry forward of Federal Work-Study funds into the next award year without proper approval.
  • Impacted Requirements: Compliance with FWS regulations (34 CFR 675.18(b)) regarding fund carry forward and reporting.
  • Recommended Follow-Up: Improve policies and procedures for FWS fund administration to ensure necessary approvals are obtained before exceeding the carry forward limit.

Finding Text

Program Information: Federal Work-Study Program (“FWS”) (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed and Unallowed/L. Reporting - An institution may carry forward and expend in the next award year up to 10% of the sum of its initial and supplemental FWS allocations for the current award year (34 CFR 675.18(b)). Condition: During our testing of the University’s FWS expenditures, we noted that the University carried forward more than the allowable 10% of its FWS allocation into the subsequent award year and did not submit the reallocation form to the Department of Education prior to the submission of the University’s Fiscal Operations Report and Application to Participate (“FISAP”). Cause: Administrative oversight with respect to accurate administration and disbursement of FWS awards. Effect or Potential Effect: The University is not in compliance with FWS requirements. Questioned Costs: None. Context: We tested the University’s compliance with FWS carry forward requirements and identified that the University exceeded the allowable 10% FWS carry forward threshold without obtaining the appropriate approvals from the Department of Education. Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance is policies and procedures related to the accurate administration and disbursement of FWS awards to ensure that the appropriate approval is obtained prior to the carry forward of amounts that exceed the allowable threshold.   Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward.

Corrective Action Plan

Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward. Anticipated Completion Date: June 30, 2024

Categories

Student Financial Aid Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 395175 2023-001
    - Repeat
  • 395177 2023-003
    -
  • 395178 2023-003
    -
  • 395179 2023-004
    -
  • 395180 2023-005
    Significant Deficiency
  • 395181 2023-007
    Significant Deficiency
  • 395182 2023-005
    Significant Deficiency
  • 395183 2023-005
    Significant Deficiency
  • 395184 2023-005
    Significant Deficiency
  • 395185 2023-005
    Significant Deficiency
  • 971617 2023-001
    - Repeat
  • 971618 2023-002
    -
  • 971619 2023-003
    -
  • 971620 2023-003
    -
  • 971621 2023-004
    -
  • 971622 2023-005
    Significant Deficiency
  • 971623 2023-007
    Significant Deficiency
  • 971624 2023-005
    Significant Deficiency
  • 971625 2023-005
    Significant Deficiency
  • 971626 2023-005
    Significant Deficiency
  • 971627 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Loan Program $5.77M
84.063 Federal Pell Grant Program $3.38M
84.031B Title III Strengthening Historically Black Colleges and Universities Program $2.82M
84.007 Federal Supplemental Educational Opportunity Grants $879,598
11.802 Mbda - Creating the Business Innovation Gateway (big) $503,224
15.904 Historic Preservation Fund - Rehabilitation of Tupper Memorial and Estey Halls $309,385
84.033 Federal Work-Study Program $307,943
84.425J Education Stabilization Fund - Higher Education Emergency Relief Fund Historically Black Colleges and Universities $261,240
11.028 Ntia - Building Bridges C.o.d.e. $165,206
93.323 Emergency Response $162,941
93.575 North Carolina Early Childhood Stabilization Grant $100,808
16.525 Doj-Rise Grant - Be the Change $100,693
47.076 Catalyst: Increasing Access and Inclusiveness in Cybersecurity $51,635
93.391 Live Well Wake $49,137
93.391 Hbcu Health Data $38,422
47.076 Ria - Antimicrobial Resistance $34,465
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities $25,973
45.309 Museum Grants for African American History and Culture $25,727
84.349 Early Childhood Educator Professional Development Program - Cda Grant $5,243