Finding Text
2024-004 Segregation of Duties
Compliance Requirement Level of Effort
Finding Type Significant Deficiency in Internal Controls
Federal Agency US Department of Education
ALN 84.031
Federal Program Higher Education Institutional Aid
Criteria
2 CFR § 200.303, Internal controls.
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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
In one instance, we identified a level of effort report without the proper approval.
Cause
Recent transition of personnel into a new leadership role contributing to the oversight.
Effect
Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls.
Questioned Costs
None.
Recommendation
We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer.
Views of Responsible Officials
Refer to Corrective Action Plan (Unaudited)