FAC Explorer

Finding 625973 (2022-004)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 47967
Organization: Western Michigan University (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The University failed to submit accurate and timely reports for the COVID-19 Education Stabilization Fund, leading to material weaknesses and noncompliance.
  • Impacted Requirements: Reports were not filed as required by the CARES Act and related regulations, with multiple errors identified in quarterly and annual submissions.
  • Recommended Follow-Up: Implement stronger controls for report accuracy and timeliness, and conduct secondary reviews of future submissions to prevent similar issues.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.

Categories

Matching / Level of Effort / Earmarking Material Weakness Reporting

Other Findings in this Audit

  • 49519 2022-002
    Material Weakness Repeat
  • 49520 2022-003
    Material Weakness Repeat
  • 49521 2022-005
    Significant Deficiency
  • 49522 2022-001
    Significant Deficiency
  • 49523 2022-002
    Material Weakness Repeat
  • 49524 2022-003
    Material Weakness Repeat
  • 49525 2022-005
    Significant Deficiency
  • 49526 2022-001
    Significant Deficiency
  • 49527 2022-002
    Material Weakness Repeat
  • 49528 2022-003
    Material Weakness Repeat
  • 49529 2022-005
    Significant Deficiency
  • 49530 2022-004
    Material Weakness
  • 49531 2022-004
    Material Weakness
  • 625961 2022-002
    Material Weakness Repeat
  • 625962 2022-003
    Material Weakness Repeat
  • 625963 2022-005
    Significant Deficiency
  • 625964 2022-001
    Significant Deficiency
  • 625965 2022-002
    Material Weakness Repeat
  • 625966 2022-003
    Material Weakness Repeat
  • 625967 2022-005
    Significant Deficiency
  • 625968 2022-001
    Significant Deficiency
  • 625969 2022-002
    Material Weakness Repeat
  • 625970 2022-003
    Material Weakness Repeat
  • 625971 2022-005
    Significant Deficiency
  • 625972 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $95.95M
84.063 Federal Pell Grant Program $18.37M
84.038 Federal Perkins Loan Program $4.16M
59.075 Covid-19 - Shuttered Venue Operators Grant Program $2.86M
84.423 Supporting Effective Educator Development Program $1.55M
84.007 Federal Supplemental Educational Opportunity Grants $1.16M
84.365 English Language Acquisition State Grants $669,901
84.336 Teacher Quality Partnership Grants $639,880
84.033 Federal Work-Study Program $612,467
84.327 Special Education_educational Technology Media, and Materials for Individuals with Disabilities $558,371
84.425 Covid-19 - Education Stabilization Fund $415,350
93.732 Mental and Behavioral Health Education and Training Grants $352,647
84.042 Trio_student Support Services $339,205
84.149 Migrant Education_college Assistance Migrant Program $300,419
84.335 Child Care Access Means Parents in School $239,484
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $193,477
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $180,845
84.129 Rehabilitation Long-Term Training $161,088
43.001 Science $150,850
84.215 Fund for the Improvement of Education $146,617
93.865 Child Health and Human Development Extramural Research $142,938
59.037 Small Business Development Centers $137,262
93.859 Biomedical Research and Research Training $134,165
12.420 Military Medical Research and Development $133,131
93.867 Vision Research $128,281
12.800 Air Force Defense Research Sciences Program $106,788
81.087 Renewable Energy Research and Development $96,403
20.109 Air Transportation Centers of Excellence $91,299
93.173 Research Related to Deafness and Communication Disorders $83,991
81.086 Conservation Research and Development $83,142
43.012 Space Technology $76,473
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $72,106
93.136 Injury Prevention and Control Research and State and Community Based Programs $65,133
84.031 Higher Education_institutional Aid $63,449
93.855 Allergy, Immunology and Transplantation Research $62,387
45.163 Promotion of the Humanities_professional Development $61,886
47.070 Computer and Information Science and Engineering $60,454
81.089 Fossil Energy Research and Development $47,926
15.814 National Geological and Geophysical Data Preservation Program $34,627
81.049 Office of Science Financial Assistance Program $34,476
98.001 Usaid Foreign Assistance for Programs Overseas $34,203
12.750 Uniformed Services University Medical Research Projects $33,824
93.279 Drug Abuse and Addiction Research Programs $31,058
47.050 Geosciences $27,498
93.110 Maternal and Child Health Federal Consolidated Programs $26,015
47.049 Mathematical and Physical Sciences $24,982
11.417 Sea Grant Support $24,894
10.572 Wic Farmers' Market Nutrition Program (fmnp) $23,560
47.076 Education and Human Resources $19,773
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $19,596
12.910 Research and Technology Development $19,321
47.041 Engineering $14,568
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $14,450
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $14,134
93.994 Maternal and Child Health Services Block Grant to the States $13,218
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $11,838
45.130 Promotion of the Humanities_challenge Grants $11,634
15.808 U.s. Geological Survey_ Research and Data Collection $10,515
84.047 Trio_upward Bound $10,161
93.926 Healthy Start Initiative $10,082
45.129 Promotion of the Humanities_federal/state Partnership $7,335
15.810 National Cooperative Geologic Mapping Program $7,127
84.305 Education Research, Development and Dissemination $6,228
47.074 Biological Sciences $5,742
81.GSA_MIGRATION U.s. Department of Energy $5,373
43.008 Education $4,954
15.657 Endangered Species Conservation ? Recovery Implementation Funds $4,944
16.585 Drug Court Discretionary Grant Program $1,368
47.075 Social, Behavioral, and Economic Sciences $189
84.016 Undergraduate International Studies and Foreign Language Programs $-20,447