EIN: 042111203
UEI: LD3WUVEUK2N5
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 25, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 25, 2022 (1580 days ago).
What is a management decision? →SECTION 3 - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING 2021 - 001: Subrecipient monitoring and Reporting (Significant Deficiency) Federal Program-> Research and Development Cluster Department of Labor, Scaling Apprenticeship through Sector-Based Strategies (Assistance Listing Number 17.268) Program year June 1, 2020 through May 31, 2021 Criteria When entering a contractual relationship with another entity, it must be first determined whether that relationship is a subrecipient or a contractor relationship. Per 29 CFR ? 99.105 a subrecipient is a non- Federal entity that expends Federal awards received from a pass-through entity to carry out a Federal program, but does not include an individual that is a beneficiary of such a program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. A contractor is a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of a Federal program. These goods or services may be for an organization's own use or for the use of beneficiaries of the Federal program. Per 2CFR ? 200.331 Subrecipient and contractor determinations: The non-Federal entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor, depending on the substance of its agreements with Federal awarding agencies and passthrough entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. The Federal awarding agency may supply and require recipients to comply with additional guidance to support these determinations provided such guidance does not conflict with this section. Context When new federal grant agreements are reviewed to identify subrecipients vs contractors, the Director of Sponsored Programs & Research reviews the contract to determine the proper classification. Upon determining the classification, the contract is sent to the Controller?s Office for verification and coding as a subrecipient or contractor in the system of record. Condition and Effect In a sample of four subrecipients selected for testing, for one of the four subrecipients, there was no contemporaneous documentation by the University of the assessment of the classification of a third party receiving funds from the University associated with this award as a subrecipient vs a contractor. Upon review of the nature of the relationship, the third party was correctly treated as a contractor by the University. However, the relationship was incorrectly classified as a subrecipient within the system of record used to prepare the SEFA. Contemporaneous documentation of the evaluation of the relationship is an important element of internal controls over subrecipient monitoring, as evidence that proper controls are in place and operating effectively. The Schedule of Expenditures of Federal Awards included disclosures that were inaccurate related to subrecipient payments in the amount of $1.235 million. Clark University SCHEDULE OF FINDINGS AND QUESTIONED COSTS - CONTINUED For the Year Ended May 31, 2021 46 Cause Due to the size of this contract the University used an account code in the system of record typically reserved for subrecipients to monitor activity, which resulted in this contractor initially being included in the list of subrecipients used to prepare the SEFA. Management has been making the determinations of the classification between subrecipient and contractor for each award, but did not document these evaluations sufficiently for audit purposes Recommendation We recommend that the University establish a formal subrecipient vs contractor checklist that compares the factors considered when evaluating the relationship, and tracking of the classification. This should be completed by the Principal Investigator or the Director of Sponsored Programs & Research and confirmed by the Controller?s Office before being uploaded to the system of record, at the beginning of the award period and before expenditures with the third party are incurred. Questioned Costs None noted Views of Responsible Officials Management concurs with the finding and recommendation, and will take corrective actions to change the coding on this contract in our system of record and implement controls to ensure that identification of subrecipients versus contractors is accurate and properly documented. Recurring Finding No
Show full finding ▾Hide full finding ▴SECTION 3 - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING 2021 - 001: Subrecipient monitoring and Reporting (Significant Deficiency) Federal Program-> Research and Development Cluster Department of Labor, Scaling Apprenticeship through Sector-Based Strategies (Assistance Listing Number 17.268) Program year June 1, 2020 through May 31, 2021 Criteria When entering a contractual relationship with another entity, it must be first determined whether that relationship is a subrecipient or a contractor relationship. Per 29 CFR ? 99.105 a subrecipient is a non- Federal entity that expends Federal awards received from a pass-through entity to carry out a Federal program, but does not include an individual that is a beneficiary of such a program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. A contractor is a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of a Federal program. These goods or services may be for an organization's own use or for the use of beneficiaries of the Federal program. Per 2CFR ? 200.331 Subrecipient and contractor determinations: The non-Federal entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor, depending on the substance of its agreements with Federal awarding agencies and passthrough entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. The Federal awarding agency may supply and require recipients to comply with additional guidance to support these determinations provided such guidance does not conflict with this section. Context When new federal grant agreements are reviewed to identify subrecipients vs contractors, the Director of Sponsored Programs & Research reviews the contract to determine the proper classification. Upon determining the classification, the contract is sent to the Controller?s Office for verification and coding as a subrecipient or contractor in the system of record. Condition and Effect In a sample of four subrecipients selected for testing, for one of the four subrecipients, there was no contemporaneous documentation by the University of the assessment of the classification of a third party receiving funds from the University associated with this award as a subrecipient vs a contractor. Upon review of the nature of the relationship, the third party was correctly treated as a contractor by the University. However, the relationship was incorrectly classified as a subrecipient within the system of record used to prepare the SEFA. Contemporaneous documentation of the evaluation of the relationship is an important element of internal controls over subrecipient monitoring, as evidence that proper controls are in place and operating effectively. The Schedule of Expenditures of Federal Awards included disclosures that were inaccurate related to subrecipient payments in the amount of $1.235 million. Clark University SCHEDULE OF FINDINGS AND QUESTIONED COSTS - CONTINUED For the Year Ended May 31, 2021 46 Cause Due to the size of this contract the University used an account code in the system of record typically reserved for subrecipients to monitor activity, which resulted in this contractor initially being included in the list of subrecipients used to prepare the SEFA. Management has been making the determinations of the classification between subrecipient and contractor for each award, but did not document these evaluations sufficiently for audit purposes Recommendation We recommend that the University establish a formal subrecipient vs contractor checklist that compares the factors considered when evaluating the relationship, and tracking of the classification. This should be completed by the Principal Investigator or the Director of Sponsored Programs & Research and confirmed by the Controller?s Office before being uploaded to the system of record, at the beginning of the award period and before expenditures with the third party are incurred. Questioned Costs None noted Views of Responsible Officials Management concurs with the finding and recommendation, and will take corrective actions to change the coding on this contract in our system of record and implement controls to ensure that identification of subrecipients versus contractors is accurate and properly documented. Recurring Finding No
Corrective Action Plan: Management agrees with this finding and will establish additional control procedures over the classification of contractual relationships as subrecipients or contractors. Corrective actions will include the following: ?The coding of this contractor will be updated in the system of record so that it will no longer be included in subrecipient reporting. ?A checklist will be implemented that lists the characteristics to be considered when determining whether a contractor or subrecipient relationship exists. This checklist will be completed by the Principal Investigator or the Director of the Office of Sponsored Programs and Research and submitted to the Grant Accounting Office for review and confirmation by the Associate Controller before being entered to the system of record, and before expenditures with the third party are incurred. We expect to fully implement these new procedures no later than October 1, 2021. Responsible person: Tammy Hearnlaye, Associate Controller Email thearnlaye@clarku.edu Phone 508-793-7297
FAC accepted this audit on March 16, 2021 — management decision was due September 16, 2021.
SECTION 3 - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING 2020 ? 001: Special Tests and Provisions ? Verification Federal Programs Department of Education Student Financial Assistance Cluster (CFDA 84,268, 84.033, 84.063 and 84.007) Program Year June 1, 2019 through May 31, 2020 Criteria Per 34 CFR 668.51-668.61, the institution must establish written policies and procedures that incorporate the provisions for verifying applicant information. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. The institution shall also require applicants to verify any information used to calculate an applicant?s Expected Family Contribution (EFC) that the institution has reason to believe is inaccurate (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4). Context If a student is selected for verification, Banner (the University?s ERP) and PowerFAIDS (the University student financial aid system) will denote this in the students account from information that is received directly from the Central Processing System (CPS). Until the verification process is completed for students, Banner and PowerFAIDS will not allow any federal aid to be released to the student's account. To comply with the criteria cited above, the University financial aid staff checks off or initials verification forms, and also saves email correspondence to indicate who from the financial aid staff approved the completion of the students? verification process. The verification forms and email correspondence with students are reviewed by the counselors as they are input into the verification detail prepared by the staff. When students submit verification forms that are incomplete, the University contacts the student upon reviewing the file to request additional information. There are instances where students return verification documents that are not complete and if this occurs, the counselors will not input any information into the system until the missing items are received. Additional system-generated notices are sent to the students who are still missing information. Once all relevant information is received and reviewed by the counselor, the student is marked as having the verification process completed. Condition and Effect In a sample of 45 verified students, 4 samples contained inaccurate information on the ISIR according to the students? submitted verification documents. This resulted in inaccurate data within the system pertaining to these students. Based on review of the submitted materials and amounts awarded, there were no instances in which the awarded amounts were incorrect; the amount awarded matched the amount qualified for based on the students? verification documents. Cause The 4 students? ISIR information was incorrect due to the financial aid department failing to correct system data after the students? supporting documents had been verified. CLARK UNIVERSITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS - CONTINUED For the year ended May 31, 2020 47 Recommendation We recommend that the University establish a tracking system that denotes the status of each student within the verification process, to avoid missing steps such as updating the ISIR once verification documents have been obtained. Additionally, we recommend that every verification have an acknowledgement of verification sent to the Director of Financial Aid to certify that the verification process was completed in full. Questioned Costs None noted Views of Responsible Officials Management concurs with the finding and recommendation. Recurring Finding No
Show full finding ▾Hide full finding ▴SECTION 3 - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING 2020 ? 001: Special Tests and Provisions ? Verification Federal Programs Department of Education Student Financial Assistance Cluster (CFDA 84,268, 84.033, 84.063 and 84.007) Program Year June 1, 2019 through May 31, 2020 Criteria Per 34 CFR 668.51-668.61, the institution must establish written policies and procedures that incorporate the provisions for verifying applicant information. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. The institution shall also require applicants to verify any information used to calculate an applicant?s Expected Family Contribution (EFC) that the institution has reason to believe is inaccurate (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4). Context If a student is selected for verification, Banner (the University?s ERP) and PowerFAIDS (the University student financial aid system) will denote this in the students account from information that is received directly from the Central Processing System (CPS). Until the verification process is completed for students, Banner and PowerFAIDS will not allow any federal aid to be released to the student's account. To comply with the criteria cited above, the University financial aid staff checks off or initials verification forms, and also saves email correspondence to indicate who from the financial aid staff approved the completion of the students? verification process. The verification forms and email correspondence with students are reviewed by the counselors as they are input into the verification detail prepared by the staff. When students submit verification forms that are incomplete, the University contacts the student upon reviewing the file to request additional information. There are instances where students return verification documents that are not complete and if this occurs, the counselors will not input any information into the system until the missing items are received. Additional system-generated notices are sent to the students who are still missing information. Once all relevant information is received and reviewed by the counselor, the student is marked as having the verification process completed. Condition and Effect In a sample of 45 verified students, 4 samples contained inaccurate information on the ISIR according to the students? submitted verification documents. This resulted in inaccurate data within the system pertaining to these students. Based on review of the submitted materials and amounts awarded, there were no instances in which the awarded amounts were incorrect; the amount awarded matched the amount qualified for based on the students? verification documents. Cause The 4 students? ISIR information was incorrect due to the financial aid department failing to correct system data after the students? supporting documents had been verified. CLARK UNIVERSITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS - CONTINUED For the year ended May 31, 2020 47 Recommendation We recommend that the University establish a tracking system that denotes the status of each student within the verification process, to avoid missing steps such as updating the ISIR once verification documents have been obtained. Additionally, we recommend that every verification have an acknowledgement of verification sent to the Director of Financial Aid to certify that the verification process was completed in full. Questioned Costs None noted Views of Responsible Officials Management concurs with the finding and recommendation. Recurring Finding No
Corrective Action Plan: Management agrees with this finding and will establish additional tracking and verification procedures to ensure that the ISIR is accurately updated once verification documents have been obtained. These procedures will include the following: ? All ISIR data and corrections will be reviewed and verified by Financial Aid Counselors. ? Reconciliation of information included in the student file, the financial aid system, and the ISIR will be performed to verify accuracy and consistency. ? An acknowledgement of verification will be sent to the Director of Financial Aid to certify that the verification process was completed in full. We expect to fully implement these new procedures no later than May 30, 2021. Responsible person: Jennifer Lawton, Director of Financial Assistance Email jlawton@clarku.edu Phone 413-522-2885
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