Finding 544142 (2024-002)

Material Weakness
Requirement
CELN
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: Internal controls over Federal awards are ineffective due to inadequate segregation of duties and lack of documentation for reviews.
  • Impacted Requirements: Compliance with 2 CFR section 200.303(a) and internal control standards is not met, risking errors and fraud.
  • Recommended Follow-Up: The University should reassess and strengthen its internal controls to ensure compliance and protect assets.

Finding Text

Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: 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: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Student Financial Aid Internal Control / Segregation of Duties Cash Management Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 544138 2024-002
    Material Weakness
  • 544139 2024-003
    Significant Deficiency
  • 544140 2024-005
    Significant Deficiency Repeat
  • 544141 2024-006
    Significant Deficiency
  • 544143 2024-003
    Significant Deficiency
  • 544144 2024-005
    Significant Deficiency Repeat
  • 544145 2024-006
    Significant Deficiency
  • 544146 2024-002
    Material Weakness
  • 544147 2024-003
    Significant Deficiency
  • 544148 2024-005
    Significant Deficiency Repeat
  • 544149 2024-006
    Significant Deficiency
  • 544150 2024-002
    Material Weakness
  • 544151 2024-003
    Significant Deficiency
  • 544152 2024-005
    Significant Deficiency Repeat
  • 544153 2024-006
    Significant Deficiency
  • 544154 2024-002
    Material Weakness
  • 544155 2024-004
    Significant Deficiency
  • 544156 2024-006
    Significant Deficiency
  • 544157 2024-002
    Material Weakness
  • 544158 2024-006
    Significant Deficiency
  • 544159 2024-007
    Significant Deficiency
  • 544160 2024-007
    Significant Deficiency
  • 1120580 2024-002
    Material Weakness
  • 1120581 2024-003
    Significant Deficiency
  • 1120582 2024-005
    Significant Deficiency Repeat
  • 1120583 2024-006
    Significant Deficiency
  • 1120584 2024-002
    Material Weakness
  • 1120585 2024-003
    Significant Deficiency
  • 1120586 2024-005
    Significant Deficiency Repeat
  • 1120587 2024-006
    Significant Deficiency
  • 1120588 2024-002
    Material Weakness
  • 1120589 2024-003
    Significant Deficiency
  • 1120590 2024-005
    Significant Deficiency Repeat
  • 1120591 2024-006
    Significant Deficiency
  • 1120592 2024-002
    Material Weakness
  • 1120593 2024-003
    Significant Deficiency
  • 1120594 2024-005
    Significant Deficiency Repeat
  • 1120595 2024-006
    Significant Deficiency
  • 1120596 2024-002
    Material Weakness
  • 1120597 2024-004
    Significant Deficiency
  • 1120598 2024-006
    Significant Deficiency
  • 1120599 2024-002
    Material Weakness
  • 1120600 2024-006
    Significant Deficiency
  • 1120601 2024-007
    Significant Deficiency
  • 1120602 2024-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.42M
84.063 Federal Pell Grant Program $1.25M
84.038 Federal Perkins Loan Program_federal Capital Contributions $632,870
84.007 Federal Supplemental Educational Opportunity Grants $89,142
93.364 Nursing Student Loans $50,104
84.033 Federal Work-Study Program $49,443
64.028 Post-9/11 Veterans Educational Assistance $36,927