Federal Program Information:
Connecting Minority Communities Pilot Program (“CMC”) (ALN: 11.028), Higher Education Institutional Aid (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations.
For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
Cause:
Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements.
Effect or Potential Effect:
The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year.
Questioned Costs:
Indeterminable.
Context:
We noted the following exceptions during our testing:
• For 1 of 22 non-payroll CMC expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds.
• For 1 of 22 non-payroll CMC expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
• For 3 of 22 non-payroll CMC expenditures selected for testing, the sampled expenditure was improperly duplicated in the system and charged to the federal award more than once.
• For 3 of 3 payroll CMC expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
• For 3 of 3 payroll CMC expenditures selected for testing, time and effort reports certified by the employee were not certified timely.
• For 2 of 3 payroll CMC expenditures selected for testing, the level of effort certified by the employee was not commensurate with amounts charged to the federal award.
• For 1 of 15 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
• For 1 of 15 payroll Title III expenditures selected for testing, the time and effort report certified by the employee was not certified timely.
• For 4 of 15 payroll Title III expenditures selected for testing, the University was unable to support that the related employee was approved to work on the grant.
• For 1 of 15 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds.
• For 2 of 15 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
• For 2 of 25 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award.
• For 24 of 25 payroll TRIO expenditures selected for testing, time and effort reports certified by the employee were not certified timely.
• For 3 of 25 payroll TRIO expenditures selected for testing, the University was unable to support that the related employee was approved to work on the grant at the level of effort certified by the employee.
• For 1 of 25 payroll TRIO expenditures selected for testing, time and effort certified by the employee did not support the amounts charged to the federal award.
Identification as a Repeat Finding:
This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation:
We recommend that the University enhance its internal controls and implement formal policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time and effort reporting in a timely manner.
Views of Responsible Officials:
The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs over the last few fiscal years. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide.
During the Spring of 2024 the University began work to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support expenditures was properly maintained, and to ensure that level of effort reporting appropriately documented and timely completed. While there were some improvements (i.e., level of effort reporting), issues were not fully remediated.
The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported.
The level of effort reporting process has been modified to a consistent reporting for all campus awards. Level of Effort reports are done by academic term, and the reports are due within 30 days following the end of the term. The Office of Government Sponsored Programs (“GSPAR”) has implemented monitoring and tracking measures to all reports are captured and completed according to federal guidelines. A system of multiple reviews has been implemented to help in reducing errors in reporting and increase efficiency in timeliness of the reports. Additionally, GSPAR intend to work closely with the JCSU Human Resources department to ensure accurate and efficient Time and Effort reporting.
In addition, the University mandated participation in compliance training for all faculty and staff; participants are required to submit an acknowledgement that they participated in the training and are aware of the compliance requirement.
Specific to the TRIO programs, as the result of a re-organization in February 2025 the University created a new position: Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being. This role will oversee Time and Effort Reporting, Annual Performance Report submissions, and financial transactions, ensuring accuracy and adherence to all relevant policies, regulations, and procedures. Additionally, this position will support professional development initiatives to enhance grant management and compliance. The AVP will also support university efforts to conduct regular program reviews to ensure proper documentation supporting TRIO eligibility and adherence to program requirements.
To improve program knowledge and standardize practices, TRIO personnel will continue engaging in professional development offered locally and nationally. Internally, the TRIO Leadership Team (TRIO Project Directors and SVP of Student Enrollment & Retention Management) established TRIO Professional Development Day, a two-day training designed specifically for JCSU TRIO staff. These sessions provide guidance on university policies, financial compliance, Time and Effort reporting, effective record-keeping, and data management. The event also includes a roundtable discussion to promote collaboration and shared learning across programs. In addition, the TRIO Leadership Team will continue to explore best practices from high-functioning TRIO programs.
To enhance communication and strengthen internal controls, the TRIO Leadership Team implemented monthly TRIO Program meetings. These meetings, involving TRIO Project Directors and the Senior Vice President of Strategic Enrollment and Retention Management, facilitate discussions on compliance, streamline processes, and support policy development. Additionally, the TRIO Leadership Team established monthly interdepartmental meetings among TRIO programs, the Division of Government Sponsored Programs and Research, and the Division of Business and Finance to further ensure alignment with institutional and federal requirements. Human Resources will also participate in future meetings to review Time and Effort Reporting procedures.
TRIO Project Directors maintain ongoing communication with the Department of Education Program Officer, seeking written guidance on allowable costs, staffing adjustments, and fund reallocations, when necessary.
Continuous monitoring and evaluation will ensure the effectiveness of these corrective actions, allowing the university to identify areas for ongoing improvement and maintain full compliance with all regulatory requirements.