Finding 401136 (2023-002)

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Requirement
P
Questioned Costs
-
Year
2023
Accepted
2024-06-18

AI Summary

  • Core Issue: The University failed to obtain voluntary consent for electronic transactions from 21 out of 25 sampled students during the 2022-23 academic year.
  • Impacted Requirements: Compliance with the E-Sign Act, which mandates obtaining student consent for electronic transactions under Federal Student Aid programs.
  • Recommended Follow-Up: Continuously evaluate the effectiveness of the updated consent process implemented for the 2023-24 academic year.

Finding Text

Finding 2023-002 – E-Sign Act Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: All Award Name: Not applicable Award Identifying Number: Not applicable Award Year: 2022-23 Academic Year Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act) Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year. Questioned Costs: None Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $160.53M
84.063 Federal Pell Grant Program $25.37M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $13.20M
93.680 Medical Student Education $7.07M
93.184 Disabilities Prevention $5.73M
93.398 Cancer Research Manpower $2.39M
93.273 Alcohol Research Programs $1.83M
93.262 Occupational Safety and Health Program $1.76M
84.007 Federal Supplemental Educational Opportunity Grants $1.64M
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $1.53M
93.732 Mental and Behavioral Health Education and Training Grants $1.48M
93.264 Nurse Faculty Loan Program (nflp) $1.37M
47.049 Mathematical and Physical Sciences $1.30M
93.310 Covid-19 Trans-Nih Research Support $1.30M
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $1.29M
93.600 Head Start $1.29M
93.493 Congressional Directives $1.23M
47.076 Education and Human Resources $1.11M
84.042 Trio_student Support Services $1.05M
84.033 Federal Work-Study Program $992,317
93.318 Covid-19 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $941,926
93.394 Covid-19 Cancer Detection and Diagnosis Research $931,305
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $890,221
93.978 Preventive Health Services_sexually Transmitted Diseases Research, Demonstrations, and Public Information and Education Grants $857,480
12.U01 Contract $811,596
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $781,102
93.359 Nurse Education, Practice Quality and Retention Grants $767,948
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $743,280
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $731,065
84.047 Trio_upward Bound $717,108
93.877 Autism Collaboration, Accountability, Research, Education, and Support $632,651
93.U11 Contract $624,071
93.U18 Special Federal Appropriations $588,417
12.U02 Contract $585,093
93.247 Advanced Nursing Education Grant Program $583,319
93.136 Injury Prevention and Control Research and State and Community Based Programs $552,096
93.632 Covid-19 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $529,854
84.365 English Language Acquisition State Grants $515,430
93.855 Covid-19 Allergy, Immunology and Transplantation Research $443,693
93.U19 Special Federal Appropriations $430,524
93.351 Research Infrastructure Programs $409,404
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $406,347
47.050 Geosciences $347,208
93.059 Training in General, Pediatric, and Public Health Dentistry $326,821
93.087 Enhance Safety of Children Affected by Substance Abuse $325,444
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $320,836
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $289,666
12.U03 Contract $284,307
16.838 Comprehensive Opioid Abuse Site-Based Program $282,450
16.U05 Contract $281,241
93.145 Aids Education and Training Centers $267,835
94.013 Volunteers in Service to America $255,093
84.066 Trio_educational Opportunity Centers $243,246
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $234,729
93.884 Grants for Primary Care Training and Enhancement $223,667
93.732 Covid-19 Mental and Behavioral Health Education and Training Grants $221,092
84.425 Education Stabilization Fund $216,801
84.305 Education Research, Development and Dissemination $216,723
93.917 Hiv Care Formula Grants $203,691
93.336 Behavioral Risk Factor Surveillance System $202,852
47.075 Social, Behavioral, and Economic Sciences $200,617
20.701 University Transportation Centers Program $196,228
93.315 Rare Disorders: Research, Surveillance, Health Promotion, and Education $172,855
59.075 Covid-19 Shuttered Venue Operators Grant Program $171,507
81.135 Advanced Research Projects Agency - Energy $164,406
47.079 Office of International Science and Engineering $159,108
93.225 National Research Service Awards_health Services Research Training $156,223
93.068 Chronic Diseases: Research, Control, and Prevention $153,703
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B (b) $149,999
93.U15 Unknown $148,099
16.839 Stop School Violence $146,575
11.023 Science, Technology, Engineering, and Mathematics (stem) Talent Challenge Program $146,006
81.112 Stewardship Science Grant Program $142,492
81.086 Conservation Research and Development $134,680
93.879 Medical Library Assistance $129,513
12.910 Research and Technology Development $123,936
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $118,409
93.860 Emerging Infections Sentinel Networks $116,778
87.U09 Contract $116,757
16.585 Drug Court Discretionary Grant Program $105,481
12.U04 Contract $98,500
84.335 Child Care Access Means Parents in School $98,276
93.600 Covid-19 Head Start $86,083
93.124 Nurse Anesthetist Traineeships $84,770
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $84,399
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $83,281
12.800 Air Force Defense Research Sciences Program $81,666
93.067 Global Aids $81,452
93.658 Foster Care_title IV-E $78,443
93.113 Environmental Health $77,113
93.137 Community Programs to Improve Minority Health Grant Program $76,203
43.008 Education $72,046
47.074 Biological Sciences $71,039
10.310 Agriculture and Food Research Initiative (afri) $70,338
77.008 U.s. Nuclear Regulatory Commission Scholarship and Fellowship Program $69,320
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $67,176
84.200 Graduate Assistance in Areas of National Need $65,561
93.767 Children's Health Insurance Program $65,448
93.889 National Bioterrorism Hospital Preparedness Program $65,306
16.U06 Contract $63,052
93.624 Aca - State Innovation Models: Funding for Model Design and Model Testing Assistance $62,044
10.855 Distance Learning and Telemedicine Loans and Grants $56,572
93.173 Research Related to Deafness and Communication Disorders $54,431
15.645 Marine Turtle Conservation Fund $46,590
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $42,906
47.070 Computer and Information Science and Engineering $42,174
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $38,862
47.084 Nsf Technology, Innovation, and Partnerships $38,853
93.940 Hiv Prevention Activities_health Department Based $37,781
93.310 Trans-Nih Research Support $34,004
81.049 Office of Science Financial Assistance Program $33,037
47.083 Integrative Activities $33,005
84.217 Trio_mcnair Post-Baccalaureate Achievement $32,703
11.609 Measurement and Engineering Research and Standards $31,531
19.009 Academic Exchange Programs - Undergraduate Programs $30,896
87.U10 Contract $30,147
43.003 Exploration $28,376
93.516 Affordable Care Act (aca) Public Health Training Centers Program $26,000
93.941 Hiv Demonstration, Research, Public and Professional Education Projects $20,428
93.396 Cancer Biology Research $20,288
93.250 Geriatric Academic Career Awards Department of Health and Human Services (b) $19,664
12.RD Contract $17,596
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $17,446
11.454 Unallied Management Projects $17,372
93.U12 Contract $16,558
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $15,853
11.463 Habitat Conservation $15,693
93.434 Every Student Succeeds Act/preschool Development Grants $14,118
93.397 Cancer Centers Support Grants $12,555
84.367 Improving Teacher Quality State Grants $12,405
10.RD Unknown $11,732
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $11,637
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $11,484
93.U13 Contract $10,533
93.U14 Contract $9,154
98.006 Foreign Assistance to American Schools and Hospitals Abroad (asha) $8,512
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs $8,414
93.809 National Organizations for Chronic Disease Prevention and Health Promotion $8,187
12.900 Language Grant Program $7,963
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $7,748
93.U16 Unknown $7,643
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $7,619
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $7,500
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $7,277
93.103 Food and Drug Administration_research $6,183
93.994 Maternal and Child Health Services Block Grant to the States $6,165
93.135 Covid-19 Centers for Research and Demonstration for Health Promotion and Disease Prevention $5,880
93.213 Research and Training in Complementary and Integrative Health $5,769
93.217 Family Planning_services $5,707
93.U17 Unknown $5,675
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $5,098
45.024 Promotion of the Arts_grants to Organizations and Individuals $5,014
64.U07 Contract $4,502
43.001 Science $4,420
93.251 Early Hearing Detection and Intervention $3,954
93.325 Paralysis Resource Center $3,699
64.U08 Contract $3,682
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $3,601
93.127 Emergency Medical Services for Children $3,298
11.482 Coral Reef Conservation Program $2,986
20.RD Contract $2,365
93.307 Minority Health and Health Disparities Research $1,642
93.RD Unknown $1,298
47.041 Engineering $1,266
12.750 Uniformed Services University Medical Research Projects $1,113
20.215 Highway Training and Education $888
93.431 Networking2save”: Cdc’s National Network Approach to Preventing and Controlling Tobacco-Related Cancers in Special Populations $864
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $780
93.859 Biomedical Research and Research Training $718
81.RD Contract $682
43.RD Contract $548
93.350 National Center for Advancing Translational Sciences $293
81.089 Fossil Energy Research and Development $282
93.867 Vision Research $59
93.279 Drug Abuse and Addiction Research Programs $38
93.991 Preventive Health and Health Services Block Grant $24
84.038 Federal Perkins Loans $0
93.408 Nurse Faculty Loan Program (nflp) Aara $0
93.865 Child Health and Human Development Extramural Research $-15
93.365 Sickle Cell Treatment Demonstration Program $-24
93.233 National Center on Sleep Disorders Research $-30
93.394 Cancer Detection and Diagnosis Research $-75
93.350 Covid-19 National Center for Advancing Translational Sciences $-87
93.361 Nursing Research $-238
93.226 Research on Healthcare Costs, Quality and Outcomes $-581
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $-660
21.019 Covid-19 Coronavirus Relief Fund $-866
93.242 Mental Health Research Grants $-1,367
93.989 International Research and Research Training $-1,415
93.837 Cardiovascular Diseases Research $-1,652
93.855 Allergy, Immunology and Transplantation Research $-2,466
93.121 Oral Diseases and Disorders Research $-2,533
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $-2,696
93.110 Maternal and Child Health Federal Consolidated Programs $-2,977
93.172 Human Genome Research $-3,348
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $-4,732
93.399 Cancer Control $-5,166
93.393 Cancer Cause and Prevention Research $-9,771
64.RD Contract $-9,853
93.RD Contract $-11,036
93.461 Covid-19 Testing for the Uninsured $-16,705
93.866 Aging Research $-18,079
84.027 Special Education_grants to States $-20,763
93.838 Lung Diseases Research $-22,058
93.839 Blood Diseases and Resources Research $-22,493
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $-26,302
93.395 Cancer Treatment Research $-34,321
12.420 Military Medical Research and Development $-98,618