Finding 994658 (2022-003)

Significant Deficiency Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-06-11
Audit: 312179
Organization: Heritage University (WA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University failed to conduct a required risk assessment and monitor its subrecipient, violating 2 CFR 200.332 (b) and (d).
  • Impacted Requirements: Compliance with federal monitoring standards, including reviewing financial reports and addressing deficiencies.
  • Recommended Follow-Up: Implement internal controls for risk assessment and monitoring, including regular reviews of financial and performance reports.

Finding Text

Criteria: In accordance with 2 CFR 200.332 (b) pass-thru entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and (d) pass-thru entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring must include: reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award, issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient and resolving audit findings specifically related to the subaward. Condition/context: We selected the one subrecipient that the University passed federal funding to during the year ended June 30, 2022. We requested support that the University performed a risk assessment and was monitoring the subrecipient, noting the University did not perform a risk assessment and was not monitoring the subrecipient in accordance with 2 CFR 200.332 (b) or (d).Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a clear understanding of the compliance requirements for subrecipient monitoring. The lack of subrecipient monitoring increases the risk that the subrecipient is not using the subaward for authorized purposes, in compliance with Federal statutes, regulations, or the terms and conditions of the subaward.Repeat finding: YesRecommendation: We recommend the University implement internal controls to assess the risk of the subrecipient and properly monitor any subrecipients of the University, such as reviewing single audits, financial and performance reports, or other necessary documentation of the subrecipient entity to help ensure the subrecipient is in compliance.Views of responsible officials and planned corrective actions: In agreement with the auditor?s recommendation of internal controls to properly monitor any subrecipients of the University, such as reviewing financial and performance reports of the subreceipient entity including any single audit reports. Heritage University has finalized the new ?Grant Management Policy & Procedures? manual. The grant management manual section on subrecipient is explicit about the University?s policies and procedures to ensure documentation is maintained.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 418206 2022-009
    Significant Deficiency
  • 418207 2022-010
    Significant Deficiency
  • 418208 2022-009
    Significant Deficiency
  • 418209 2022-010
    Significant Deficiency
  • 418210 2022-009
    Significant Deficiency
  • 418211 2022-002
    Material Weakness Repeat
  • 418212 2022-006
    Significant Deficiency
  • 418213 2022-007
    Material Weakness
  • 418214 2022-002
    Material Weakness Repeat
  • 418215 2022-002
    Material Weakness Repeat
  • 418216 2022-003
    Significant Deficiency Repeat
  • 418217 2022-006
    Significant Deficiency
  • 418218 2022-006
    Significant Deficiency
  • 418219 2022-007
    Material Weakness
  • 418220 2022-007
    Material Weakness
  • 418221 2022-008
    Significant Deficiency
  • 418222 2022-004
    Significant Deficiency Repeat
  • 418223 2022-005
    Material Weakness Repeat
  • 418224 2022-005
    Material Weakness Repeat
  • 418225 2022-002
    Material Weakness Repeat
  • 418226 2022-002
    Material Weakness Repeat
  • 418227 2022-002
    Material Weakness Repeat
  • 418228 2022-002
    Material Weakness Repeat
  • 418229 2022-003
    Significant Deficiency Repeat
  • 418230 2022-002
    Material Weakness Repeat
  • 418231 2022-002
    Material Weakness Repeat
  • 994648 2022-009
    Significant Deficiency
  • 994649 2022-010
    Significant Deficiency
  • 994650 2022-009
    Significant Deficiency
  • 994651 2022-010
    Significant Deficiency
  • 994652 2022-009
    Significant Deficiency
  • 994653 2022-002
    Material Weakness Repeat
  • 994654 2022-006
    Significant Deficiency
  • 994655 2022-007
    Material Weakness
  • 994656 2022-002
    Material Weakness Repeat
  • 994657 2022-002
    Material Weakness Repeat
  • 994659 2022-006
    Significant Deficiency
  • 994660 2022-006
    Significant Deficiency
  • 994661 2022-007
    Material Weakness
  • 994662 2022-007
    Material Weakness
  • 994663 2022-008
    Significant Deficiency
  • 994664 2022-004
    Significant Deficiency Repeat
  • 994665 2022-005
    Material Weakness Repeat
  • 994666 2022-005
    Material Weakness Repeat
  • 994667 2022-002
    Material Weakness Repeat
  • 994668 2022-002
    Material Weakness Repeat
  • 994669 2022-002
    Material Weakness Repeat
  • 994670 2022-002
    Material Weakness Repeat
  • 994671 2022-003
    Significant Deficiency Repeat
  • 994672 2022-002
    Material Weakness Repeat
  • 994673 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.67M
84.268 Federal Direct Student Loans $2.60M
84.141 Migrant Education_high School Equivalency Program $497,387
84.149 Migrant Education_college Assistance Migrant Program $471,081
84.042 Trio_student Support Services $282,228
84.031 Higher Education_institutional Aid $236,724
84.217 Trio_mcnair Post-Baccalaureate Achievement $234,353
93.011 National Organizations of State and Local Officials $180,020
84.007 Federal Supplemental Educational Opportunity Grants $170,371
93.732 Mental and Behavioral Health Education and Training Grants $104,094
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $84,870
47.074 Biological Sciences $66,342
84.033 Federal Work-Study Program $54,613
10.558 Child and Adult Care Food Program $26,973
43.008 Education $20,649
47.075 Social, Behavioral, and Economic Sciences $12,634
45.164 Promotion of the Humanities_public Programs $9,439
45.310 Grants to States $6,946
45.129 Promotion of the Humanities_federal/state Partnership $6,447
10.310 Agriculture and Food Research Initiative (afri) $6,425
47.076 Education and Human Resources $4,118
84.425 Education Stabilization Fund $2,804
84.038 Federal Perkins Loan Program $2,285