Finding 51862 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 43164
Organization: American Jewish University (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University lacks effective internal controls to ensure ISIR flags are cleared, risking non-compliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and internal control standards is not being met, exposing the University to potential penalties.
  • Recommended Follow-Up: Develop and document a clear process for identifying and clearing ISIR flags in the policy manual to strengthen compliance efforts.

Finding Text

FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) 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 statutes, 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/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.

Categories

Student Financial Aid Eligibility Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 51856 2022-001
    Significant Deficiency
  • 51857 2022-003
    Significant Deficiency Repeat
  • 51858 2022-004
    Significant Deficiency Repeat
  • 51859 2022-001
    Significant Deficiency
  • 51860 2022-003
    Significant Deficiency Repeat
  • 51861 2022-004
    Significant Deficiency Repeat
  • 51863 2022-003
    Significant Deficiency Repeat
  • 51864 2022-004
    Significant Deficiency Repeat
  • 51865 2022-001
    Significant Deficiency
  • 51866 2022-002
    Material Weakness Repeat
  • 51867 2022-003
    Significant Deficiency Repeat
  • 51868 2022-004
    Significant Deficiency Repeat
  • 628298 2022-001
    Significant Deficiency
  • 628299 2022-003
    Significant Deficiency Repeat
  • 628300 2022-004
    Significant Deficiency Repeat
  • 628301 2022-001
    Significant Deficiency
  • 628302 2022-003
    Significant Deficiency Repeat
  • 628303 2022-004
    Significant Deficiency Repeat
  • 628304 2022-001
    Significant Deficiency
  • 628305 2022-003
    Significant Deficiency Repeat
  • 628306 2022-004
    Significant Deficiency Repeat
  • 628307 2022-001
    Significant Deficiency
  • 628308 2022-002
    Material Weakness Repeat
  • 628309 2022-003
    Significant Deficiency Repeat
  • 628310 2022-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $768,335
84.425 Higher Education Emergency Relief Fund $151,000
84.063 Federal Pell Grant Program $24,030
84.007 Federal Supplemental Educational Opportunity Grants Program $23,010
84.033 Federal Work Study Program $19,601