University System of New HampshireHigher Education

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that ten students at Keene State College and seven students at University of New Hampshire did not have the credit balance refunded within the 14 day period. Context: The institution’s policies and procedures did not successfully track the 14 day period required for credit balance refunds. Cause: The policies and procedures of the institution did not ensure that refund compliance requirements were timely met. Questioned Costs: None Possible Asserted Effect: The institution did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: Yes – 2024-001 Auditor’s Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include accurate information. Condition: We noted, during our testing, that two students from Keene State College and two students from Plymouth State University out of 60 students tested whose enrollment status was not timely reported to NSLDS. In addition, one student’s status in NSLDS did not agree to the transcript at Plymouth State University and one student’s effective date in NSLDS did not agree to the institutional records at Plymouth State University. Context: The institution’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Cause: The institution’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Questioned Costs: None Possible Asserted Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes 2024-002 Auditor’s Recommendation: We recommend the institution review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s student aid index for that period. Condition: We noted one student from Keene State College was awarded need based aid over their calculated need. In addition, we noted, during our testing, that one student from Keene State College and one student from the University of New Hampshire whose subsidized loans were not maximized before originating an unsubsidized loan. Context: The institution’s processes and controls did not ensure that student was awarded appropriately based on the students need calculation. Cause: The institution’s processes and controls did not ensure the student was awarded need based aid up to their need calculation. Questioned Costs: None Possible Asserted Effect: Students are awarded aid beyond their need calculation. Repeat Finding: No Auditor’s Recommendation: We recommend the institution review its reporting procedures to ensure that awarding is within the need calculation. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 668.32(f), students must maintain satisfactory academic progress (SAP) in his or her course of study according to the institution’s published standards of satisfactory academic progress that meet the requirements of 34 CFR 668.34. Condition: Of the 60 students tested, we noted one student from the University of New Hampshire who was disbursed aid after failing SAP and was no longer eligible to receive federal student aid. In addition, we noted, two students from University of New Hampshire who failed SAP in Spring of 2025 and were not provided the proper notification that they had failed SAP and were no longer eligible to receive federal student aid. Context: The institution’s processes and controls did not ensure that students were properly notified they were no longer eligible and continued awarding aid to students no longer eligible. Cause: The institution’s processes and controls did not ensure the student’s failing SAP received the proper notification and eligibility terminated. Questioned Costs: None Possible Asserted Effect: Students are disbursed aid when they no longer are eligible. Repeat Finding: No Auditor’s Recommendation: We recommend the institution review its SAP policies to ensure they met the minimum requirements and that they are fully implemented. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: One of the students at the University of New Hampshire of the ten tested did not have the required support retained in the student files. Context: The University’s processes and controls did not ensure the verification process was completed before disbursements of awards. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Questioned Costs: None Possible Asserted Effect: The University did not either obtain or retain information to support the verification process. Documentation needs to be retained to show that the verification process was completed. Repeat Finding: No Auditor’s Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: July 01, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 5 students at Keene State College did not have the credit balance refunded within the 14 day period. Context: The College’s policies and procedures did not successfully track the 14 day period required for credit balance refunds Cause: The policies and procedures of the College did not ensure that refund compliance requirements were timely met. Questioned Costs: None Possible Asserted Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: No Auditor's Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: July 01, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: We noted, during our testing, that 6 out of 60 students tested whose enrollment status was not timely reported to NSLDS. Context: The College’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Cause: The College’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Questioned Costs: None Possible Asserted Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Auditor's Recommendation: We recommend the College review its reporting procedures to ensure that students' statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F203030; award year 2020-21 Award Period: July 01, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for the Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our testing of HEERF reporting requirements on the System, we noted one of the three quarterly reports tested for Granite State College was published to the College’s website outside of the 10-day timeframe requirement. Context: The College’s policies and procedures did not successfully track the compliance to reporting requirements, specifically the timely submission of the reports to the College’s website. Cause: The policies and procedures of the College did not ensure that grant reporting compliance requirements were timely met. Questioned Costs: None Possible Asserted Effect: Third parties do not have timely access to funding and expenditure information. Repeat Finding: Yes, 2022-001

2022 ? 001 Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F Award Period: July 01, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for the Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our testing of HEERF reporting requirements on the System, we noted: 1) Noncompliant Student Reporting: University of New Hampshire ? Two of the two quarterly reports tested did not have supporting documentation that agreed to the number of emergency grant eligible students and number of emergency grant recipients. ? One of the two quarterly reports tested included total emergency grant amounts for a six month period instead of only the quarter period being reported. Keene State College ? One of the one quarterly reports tested did not have evidence to support the date of upload to the College?s website. 2) Noncompliant Institutional Reporting: University of New Hampshire ? One of the one quarterly reports tested had HEERF Institutional Portion award totals that did not match the award amounts from the Grant Award Notifications. Keene State College ? One of the two quarterly reports tested was published to the College?s website outside of the 10-day timeframe requirement. Plymouth State University ? One of the one quarterly reports tested was published to the University?s website outside of the 10-day timeframe requirement. Granite State College ? One of the one quarterly reports tested had HEERF Institutional Portion award totals that did not match the award amounts from the Grant Award Notifications. 3) Noncompliant Annual Reporting: University of New Hampshire ? One of the one annual reports tested did not have supporting documentation that could corroborate all student count and student emergency grant totals. Keene State College ? One of the one annual reports tested did not have supporting documentation that agreed to the number of student emergency grant recipients. Granite State College ? One of the one annual reports tested had incorrect totals reported in the Student Portion provided directly to students reporting area. 4) Lack of Documentation of Review: University of New Hampshire Keene State College Plymouth State University Granite State College Context: The Colleges and Universities did not have a centralized process to successfully track the reporting requirements. In addition, there was a general lack of guidance from the Department of Education on reporting requirements. This led to the various issues noted above within the reports tested. Cause: The policies and procedures of the Universities and Colleges did not ensure that grant reporting compliance requirements were timely and accurately met or corroborated by supporting documentation. Questioned Costs: None Possible Asserted Effect: The documentation doesn?t support the numbers reported on the website and therefore the amounts reported on the website could be inaccurate. Repeat Finding: Yes, 2021-001 Auditor?s Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Views of Responsible Officials: There is no disagreement with the audit finding.

2021 ? 001 Federal Agency: Department of Education Federal Program Title: CARES HEERF CFDA Number: 84.425E, 84.425F Award Period: July 01, 2020 ? June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition During our testing, we noted: ? One of the four annual reports tested did not have supporting documentation that agreed to the numbers included in the report and three lacked documentation to prove a review was completed prior to posting to the website ? Two of the four quarterly institutional reports tested was not timely submitted and one of the four tested did not have supporting documentation that agreed to the numbers included in the report and two lacked documentation to prove a review was completed prior to posting to the website ? Three of the four quarterly student reports tested did not have supporting documentation that agreed to the numbers included in the report, and a lack of documentation to prove a review was completed prior to posting to the website Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the colleges and universities did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: Due to the urgency to get the information posted to the website within the 30 day timeframe, the University pulled data from their systems but failed to maintain the reports used for numbers posted to the website. The University continued to disburse funds to the students and subsequently the reports changed and the University was not able to recreate the data used for the reporting. Questioned Costs: None Possible Asserted Effect: The documentation doesn?t support the numbers reported on the website and therefore the amounts reported on the website could be inaccurate. Repeat Finding: Yes, 2020-001 Auditor?s Recommendation: We recommend the Universities and College maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website. Views of Responsible Officials: There is no disagreement with the audit finding.

2020 ? 001 Federal Agency: Department of Education Federal Program Title: CARES HEERF CFDA Number: 84.425E Award Period: July 01, 2019 ? June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter. Condition and Context: During our testing of the reports posted on the University of New Hampshire?s website, we noted the website reported $2,939,050 of emergency financial aid grants disbursed to 5,150 students. However, the detailed listings provided showed $2,670,800 disbursed to 5,433 students for a difference of $268,250 and 283 students. Cause: Due to the urgency to get the information posted to the website within the 30 day timeframe, the University pulled data from their systems but failed to maintain the reports used for numbers posted to the website. The University continued to disburse funds to the students and subsequently the reports changed and the University was not able to recreate the data used for the 30 day reporting. Questioned Costs: None Possible Asserted Effect: The documentation doesn?t support the numbers reported on the website and therefore the amounts reported on the website could be inaccurate. Repeat Finding: No Auditor?s Recommendation: We recommend the University maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website. Views of Responsible Officials: There is no disagreement with the audit finding.

Program Name: Research and Development Cluster See Schedule of Findings and Questioned Costs for table. Criteria Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Conditions Found: The Sponsored Programs Administration?s (?SPA?) Expense Approval and Documentation Guidance, ?The Principal Investigator (?PI?) has overall responsibility for the technical and fiscal management of a sponsored project. While the PI may receive assistance from the Business Service Center (?BSC?) or SPA on financial tasks, the PI retains the responsibility for the review and approval, of charges on their sponsored project(s)?. PI?s are responsible for reviewing expenditures to confirm they are allowable and allocable to the grant and are within the grants period of performance. PI?s may delegate this responsibility to an individual with direct knowledge of the project. Delegates may only approve routine items and reimbursement requests. Delegates may not approve all transactions that directly benefit the delegate. During our testwork of 40 non-payroll expenditures, we noted 3 instances where we could not determine if the PI, or their approved delegate, had expressly approved the cost. Specifically, we noted: 1) For 2 of the 3 instances noted above, the approval was completed by an approved delegate, however, the expense was directly related to the delegate and therefore, PI approval was required. These expenditures related to conference fees and hotel accommodations for the delegate to present at a scientific meeting. 2) In 1 of the 3 instances noted above, we could not determine if the PI, or their approved delegate, had expressly approved the cost. Although the PI, or their delegate, was copied on emails and had the opportunity to reject the expenditure, this opportunity does not equate to approval. Cause: The cause of the condition found appears to be a lack of required explicit approvals by the project PI for expenditures which allows for passive approval. Possible Asserted Effect The possible effect of the condition found is that unallowed costs are charged to a Federal award or costs are charged to the Federal award with the approval of the project PI. The condition found appears to be systemic in nature and is considered a significant deficiency in internal control. Questioned Costs Not Determinable. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in the prior year report as 2018-001. Recommendation We recommend the University review its policies and procedures over approvals and implement a requirement for explicit approval of expenditures. Additionally, we recommend the University implement formal procedures to prevent delegates from approving expenses directly related to the delegate. View of University Officials Following the University?s standard process, the expenditures described in this finding were reviewed and approved by two levels of Business Service Center staff assigned to the PI?s department in addition to the notification by email provided to the PI and/or their designated delegate. However, we agree with the auditor?s recommendation and will review and strengthen our policies and procedures regarding approval of expenditures. We also note that the payments in item # 1 were made directly to the hotel and conference host and did not go through the UNH staff person attending the conference.

Program Name: Research and Development Cluster See Schedule of Findings and Questioned Costs for table. Criteria: For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. See also ?200.302 Financial management paragraph (f). Except as noted elsewhere in this part, Federal agencies must require recipients to use only OMB-approved standard government-wide information collection requests to request payment (2 CFR 200.35). Interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852. Interest amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Conditions Found: The Sponsored Program Administration (?SPA?) is responsible for calculating and drawing down Federal funds. This process includes a review of the Federal draw down request to ensure it is accurate and in compliance with Federal requirements. The review process includes the segregation of duties between the preparer of the drawdown, the applier of the drawdown and the reviewer of the drawdown. During our testwork over cash management we selected a sample of 40 draws and noted the following: 1) The drawdown calculation process includes a reconciliation to identify expenditures incurred but not yet paid, however, only amounts over $5,000 are placed on hold and not included in the drawdown request until the funds have been expended. In 4 drawdown selection we noted that the draw included expenditures for which payment had not yet been made. These unpaid expenditures totaled $7,323 and could have resulted in the University receiving funds in advance of payment. We noted that the University does not prepare an annual analysis of whether interest was earned on reimbursements paid in advance and therefore required to be remitted to the US Department of Health and Human Services. 2) For 29 drawdowns we noted that the names of the preparer, applier and reviewer were either typed onto the drawdown form or each name was written by the same person. This did not allow us to re-perform the identified control to determine that there was proper segregation of duties and that a review of the draw was performed prior to the draw. Cause: The cause of the condition found is a result of the University?s internal procedures and practices which a) only requires unpaid expenditures over $5,000 to be put in hold for administrative practicality purposes; and b) do not require the segregation of duties and review control to be documented in a manner that allows for reperformance. Possible Asserted Effect: The University is requesting and receiving Federal drawdowns based on expenditures that have not yet been paid and they could draw down incorrect amounts and would not be able to make a correction until after the funds had been received. The condition found appears to be systemic in nature and is considered a significant deficiency in internal control. Questioned Costs: Not determinable. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the University reviews their policies and procedures to a) align them with Federal requirements regarding requirements related to reimbursement basis; and b) implement formal documentation requirements during each phase of the drawdown process to allow for re-performance of the segregation of duties and review controls. View of University Officials: (1) The University?s process is to draw Federal funds at the end of each month reimbursing expenses and reducing the possibility of drawing funds in advance. Management performed an analysis confirming that in aggregate, the University was never in a position of advancing federal funds at any time during FY19. However, we agree with the auditor?s recommendation and will review and revise cash management procedures to strengthen and more fully align them with Federal requirements. (2) Management agrees with the recommendation to implement formal documentation requirements. We have updated our procedure to require the preparer, reviewer, and applier, to sign and date the documentation.

Program Name: TRIO Cluster See Schedule of Findings and Questioned Costs for table. Criteria: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; and be adequately documented. (2 CFR 200.404). Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. (2 CFR 200.405). Conditions Found: We selected a sample of 120 payroll and 120 non-payroll costs charged to the TRIO program (40 of each type of cost at each of the 3 campuses administering TRIO services) and noted the following during our testwork: Plymouth State University (PSU) campus: The Director of the TRIO program reviews expenses to ensure they are allowable, allocable, and accurate and the approval is noted through a sign-off or an email confirmation. During our review of 40 non-payroll costs, we noted 7 instances where there was no documented approval by the Director indicating that the costs were allowable and allocable to the TRIO program. Cause: The cause appears to be result of the campus?s internal procedures and practices which do not require formal approval sign-off on costs. Possible Asserted Effect The possible effect of the condition found is that unallowed costs are charged to a Federal award. The condition found appears to be systemic in nature and is considered a significant deficiency in internal control. Questioned Costs: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the University review its policies and procedures regarding documentation retention and charging of costs to grant awards to ensure that direct costs can be identified specifically with a particular final cost objective. View of University Officials: PSU: Internal procedures have already changed to close any gaps in securing and/or maintaining the documentation of the PI?s approval on grant expenditures. The roll-out of the upcoming e-procurement solution will further enhance this effort.

Program Name: TRIO Cluster See Schedule of Findings and Questioned Costs for table. Criteria: For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. See also ?200.302 Financial management paragraph (f). Except as noted elsewhere in this part, Federal agencies must require recipients to use only OMB-approved standard government-wide information collection requests to request payment (2 CFR 200.35). Interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852. Interest amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Conditions Found: We selected a sample of 25 cash draws across the 3 campuses administering TRIO and noted the following during our testwork: Keene State College (KSC) campus: The KSC Sponsored Projects Office is responsible for calculating and drawing down Federal funds. This process includes a review of the Federal draw down request to ensure it is accurate and in compliance with Federal requirements. The review process includes the segregation of duties between the preparer of the drawdown and reviewer of the drawdown. During our testwork over cash management we selected a sample of 8 draws at KSC and noted the following: 1) For all 8 drawdowns we were not able to identify the two different individuals who performed the drawdown tasks (i.e. preparer and reviewer). In each case the preparer and reviewer were either typed onto the drawdown form or each name was written by the same person. This did not allow us to re-perform the identified control. 2) When determining the amount to drawdown, the KSC Sponsored Projects Office do not evaluate whether there are any unpaid expenses that need to be removed from the request. Additionally, we noted that the campus does not prepare an analysis of whether interest was earned on reimbursements paid in advance and therefore required to be remitted to the US Department of Health and Human Services. Plymouth State University (PSU) campus: The Financial Support Specialist is responsible initiating the drawing down of Federal funds. This process includes a review of the Federal draw down request to ensure it is accurate and in compliance with Federal requirements. The review process includes the segregation of duties between the preparer of the drawdown and reviewer of the drawdown. During our testwork over cash management we selected a sample of 5 draws at PSU and we were unable to identify the two different individuals who performed the drawdown tasks (i.e. preparer and reviewer). In each case the preparer and reviewer were either typed onto the drawdown form or each name was written by the same person. This did not allow us to re-perform the identified control. University of New Hampshire (UNH) campus: The Sponsored Program Administration (?SPA?) is responsible for calculating and drawing down Federal funds. This process includes a review of the Federal draw down request to ensure it is accurate and in compliance with Federal requirements. The review process includes the segregation of duties between the preparer of the drawdown, the applier of the drawdown and the reviewer of the drawdown. During our testwork over cash management we selected a sample of 12 draws and noted the following: 1) The drawdown calculation process includes a reconciliation to identify expenditures incurred but not yet paid, however, only amounts over $5,000 are placed on hold and not included in the drawdown request until the funds have been expended. In 2 drawdown selection we noted that the draw included expenditures for which payment had not yet been made. These unpaid expenditures totaled $4,117 and could have resulted in the University receiving funds in advance of payment. We noted that the University does not prepare an annual analysis of whether interest was earned on reimbursements paid in advance and therefore required to be remitted to the US Department of Health and Human Services.2) For 11 drawdowns we noted that the preparer, applier and reviewer were either typed onto the drawdown form or each name was written by the same person. This did not allow us to re-perform the identified control to determine that there was proper segregation of duties and that a review of the draw was performed prior to the draw. Cause KSC campus: The cause of the condition found is a result of the campuses? internal procedures and practices which do not require the segregation of duties and review control to be documented in a manner that allows for reperformance. Additionally, the campus was not aware that the report used to support drawdowns included unpaid costs. PSU campus: The cause of the condition found is a result of the campuses? internal procedures and practices which do not require the segregation of duties and review control to be documented in a manner that allows for reperformance. UNH campus: The cause of the condition found is a result of the University?s internal procedures and practices which a) only requires unpaid expenditures over $5,000 to be put in hold for administrative practicality purposes; and b) do not require the segregation of duties and review control to be documented in a manner that allows for reperformance. Possible Asserted Effect: The University is requesting and receiving Federal drawdowns based on expenditures that have not yet been paid and they could draw down incorrect amounts and would not be able to make a correction until after the funds had been received. The condition found appears to be systemic in nature and is considered a significant deficiency in internal control. Questioned Costs: Not determinable. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the University reviews their policies and procedures to a) align them with Federal requirements regarding requirements related to reimbursement basis; and b) implement formal documentation requirements during each phase of the drawdown process to allow for re-performance of the segregation of duties and review controls. View of University Officials: KSC: (1) We agree with the finding and will update our policies and procedures to require that the preparer and approver of all drawdown requests sign and date the related documents. (2) We agree with the recommendation and will review and revise our cash management procedures to more fully align with the federal requirements. PSU: This documentation gap has already been addressed, whereby, the Accountant in the Compliance, Analysis and Planning Office, the preparer, sends an emailed copy of the Request Acknowledgement received from the ?G5? Federal system (which includes her name imbedded in the referenced username) along with the Request Payment Confirmation notification (which states the amount of the draw requested) to the OSP Financial Support Specialist for review and posting. UNH: (1) The University?s process is to draw Federal funds at the end of each month reimbursing expenses and reducing the possibility of drawing funds in advance. Management performed an analysis confirming that in aggregate, the University was never in a position of advancing federal funds at any time during FY19. However, we agree with the auditor?s recommendation and will review and revise cash management procedures to strengthen and more fully align them with Federal requirements. (2) Management agrees with the recommendation to implement formal documentation requirements. We have updated our procedure to require the preparer, reviewer, and applier, to sign and date the documentation.

Program Name: TRIO Cluster See Schedule of Findings and Questioned Costs for table. Criteria: SSS Program Eligible Participants ? A student is eligible to participate in a SSS project if the student meets all of the following requirements: (a) is a citizen or national of the United States or meets the residency requirements for Federal student financial assistance; (b) is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution; (c) has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and (d) is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7). Grant Aid to SSS Students ? Grant aid to students is restricted to students who meet all of the following criteria: (a) participating in the SSS project, undergoing their first 2 years of postsecondary education; and (b) receiving Federal Pell Grants. In exceptional cases, grant aid may be offered to students who have completed their first 2 years of postsecondary education and are receiving Federal Pell Grants (34 CFR section 646.30(i)). The amount of grant aid awarded to an SSS student may not exceed the maximum appropriated Pell Grant ($5,815 for the 2016-2017 academic year) or be less than the minimum appropriated Pell Grant ($590 for the 2016-2017 academic year) (20 USC 1070a-14(d)(1)). Conditions Found: We selected a sample of 120 students participating in the TRIO program (40 at each of the 3 campuses administering TRIO services) and noted the following during our testwork: Plymouth State University (PSU) campus: The campus requires students requesting services and entry into the SSS program to complete an internal application form, PASS Application for Services form, which collects eligibility data. The campus then confirms eligibility using various institutional sources. We selected a sample of 40 students from the PSU campus and noted the following: 1) 15 of the 40 students were classified as being eligible, in whole or in part, based on being an individual with a disability. A participant?s disability eligibility designation is confirmed with the PSU Campus Accessibility Services department and the disability box is checked on the student?s application to document the confirmation. We noted that there is no documentation beyond this checkmark of this verification and therefore we were unable to determine this eligibility designation for these 15 students. Of these 15 students, 2 were eligible based on this designation alone and therefore we were unable to determine if these 2 students were eligible for TRIO services. 2) 35 of the students were classified as being eligible, in whole or in part, based on being a low-income individual. The campus confirms low-income status through a PASS Income Eligibility Listing query, which was created and maintained by Financial Aid department to identify income threshold reported on the participant?s FAFSA. In the query, the TRIO Director enters TRIO Program Low-Income Levels equal to 150% of the family income levels established by the Census Bureau for determining poverty status to receive a report listing of students who are TRIO low-income eligible. Students who have completed a PASS Application for Services form and are determined low-income via this query have an ?LI? entered into their PASS Web Application record to indicate eligibility based on this criteria. Of these 35 students, 2 were eligible based on the low-income designation alone; however, in reviewing the participant?s completed FAFSA we noted that the students were not actually low-income and therefore were not eligible for TRIO services. During fiscal 2018 the query parameters were inaccurately set up and in addition to the 2 ineligible students in our population, the campus identified 3 additional students who had been determined eligible based on the low-income designation alone but did not actually meet the designation. Cause: The cause for condition 1 above is a result of the campuses internal policies and procedures which do not require formal documentation be obtained from the Campus Accessibility Services department to document disability status. The cause for condition 2 above is a result of the query parameters being inaccurate which resulted in inaccurate designations. Possible Asserted Effect The possible effect of the condition found is that ineligible participants receive TRIO services. The condition found appears to be systemic in nature and is considered a significant deficiency in internal control. Questioned Costs: Not determinable. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the University review its policies and procedures regarding eligibility determination and documentation retention to ensure that participants are accurately determined eligible and that sufficient documentation is maintained to support the determination. View of University Officials: PSU: The TRIO Director will work with the Disabilities Office director to create a more formal documentation process of disability status. The query issue was resolved back in December 2018 to correct the calculation error. Beginning with the next low-income report run, a sample of the individuals identified as low-income will be tested through a manual calculation to validate the output of the report before providing services.

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