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.