EIN: 221487354
UEI: JJ6CN5Y5A2R5
Audited by: KPMG LLP
Cognizant agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 20, 2026. 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 September 20, 2026 (18 days from today).
What is a management decision? →FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
Compliance Requirement – Subrecipient Monitoring – Significant Deficiency and Noncompliance Criteria Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context We selected thirteen subrecipients for testwork out of 82 in total and we noted that the University did not properly receive and review the single audit reports for seven of those subrecipients to ensure they had no material findings that would impact the University. The University then identified an additional six subrecipients outside of our sample where the same deficiency occurred. Cause The University had turnover in staff in the Office of Sponsored Projects during the fiscal year 2024 and this led to miscommunication which resulted in this monitoring step not being performed timely. Effect Subrecipient monitoring that is not performed timely could result in federal dollars being passed down to subrecipients with significant control or compliance issues that could impact the University. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures to ensure that subrecipient monitoring is being performed timely. The University should provide training to the departments responsible for these reviews.
Show full finding ▾Hide full finding ▴Compliance Requirement – Subrecipient Monitoring – Significant Deficiency and Noncompliance Criteria Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context We selected thirteen subrecipients for testwork out of 82 in total and we noted that the University did not properly receive and review the single audit reports for seven of those subrecipients to ensure they had no material findings that would impact the University. The University then identified an additional six subrecipients outside of our sample where the same deficiency occurred. Cause The University had turnover in staff in the Office of Sponsored Projects during the fiscal year 2024 and this led to miscommunication which resulted in this monitoring step not being performed timely. Effect Subrecipient monitoring that is not performed timely could result in federal dollars being passed down to subrecipients with significant control or compliance issues that could impact the University. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures to ensure that subrecipient monitoring is being performed timely. The University should provide training to the departments responsible for these reviews.
Management agrees with the finding. The Office of Sponsored Programs will conduct a review of the subrecipient issuance and monitoring process to ensure that roles and responsibilities regarding the timely monitoring of subrecipients' single audit reports are clear and that any personnel engaged in review of the single audit reports receives training regarding these activities.
FAC accepted this audit on March 22, 2024 — management decision was due September 22, 2024.
Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected forty students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. For six enrollment status changes, the status change was not reported within 60 days. Five of these six were reported 65 days late, and the last was reported 128 days late. For four of the late enrollment status changes noted above, the changes were inaccurately reported as withdrawals, when instead, they related to a graduate status change. There was one enrollment status change that was not reported to NSLDS. Cause The University uses a system generated file to report enrollment status changes. The system generated file was not configured appropriately to flag enrollment status for students graduating from a bachelor’s program and who were enrolled in a master’s program resulting in status changes to be inaccurate and not timely reported. In addition, the one student who was not reported was due to an incorrect social security number which resulted in a processing error with National Student Clearinghouse which was not corrected by the University. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures to ensure that student enrollment changes are accurately reported to NSLDS within 60 days of the status change. The University should provide training to the departments responsible for the accuracy and timeliness of this reporting. Views of Responsible Official Management agrees with the recommendation. The University understands the importance of accurate and timely reporting of enrollment status and immediately resolved the issues of correcting student records in the NSLDS system and configured the system generated file to correct the status that is reported for students who graduate with a bachelor’s degree and continue in school to pursue a master’s degree. The University will also add a control to review processing errors from the National Student Clearinghouse submissions. The Associate Provost and Registrar will ensure that processes are in place to comply with the recommendation.
Show full finding ▾Hide full finding ▴Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected forty students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. For six enrollment status changes, the status change was not reported within 60 days. Five of these six were reported 65 days late, and the last was reported 128 days late. For four of the late enrollment status changes noted above, the changes were inaccurately reported as withdrawals, when instead, they related to a graduate status change. There was one enrollment status change that was not reported to NSLDS. Cause The University uses a system generated file to report enrollment status changes. The system generated file was not configured appropriately to flag enrollment status for students graduating from a bachelor’s program and who were enrolled in a master’s program resulting in status changes to be inaccurate and not timely reported. In addition, the one student who was not reported was due to an incorrect social security number which resulted in a processing error with National Student Clearinghouse which was not corrected by the University. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures to ensure that student enrollment changes are accurately reported to NSLDS within 60 days of the status change. The University should provide training to the departments responsible for the accuracy and timeliness of this reporting. Views of Responsible Official Management agrees with the recommendation. The University understands the importance of accurate and timely reporting of enrollment status and immediately resolved the issues of correcting student records in the NSLDS system and configured the system generated file to correct the status that is reported for students who graduate with a bachelor’s degree and continue in school to pursue a master’s degree. The University will also add a control to review processing errors from the National Student Clearinghouse submissions. The Associate Provost and Registrar will ensure that processes are in place to comply with the recommendation.
Management agrees with the recommendation. The University understands the importance of accurate and timely reporting of enrollment status and immediately resolved the issues of correcting student records in the NSLDS system and configured the system generated file to correct the status that is reported for students who graduate with a bachelor’s degree and continue in school to pursue a master’s degree. The University will also add a control to review processing errors from the National Student Clearinghouse submissions. The Associate Provost and Registrar will ensure that processes are in place to comply with the recommendation.
FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.
Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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 (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Show full finding ▾Hide full finding ▴Finding No. 2022-001 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Aid Portion, Assistance Listing 84.425E (award number P425E201772) COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-001). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings 84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, 84.425T as applicable) The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Auditors should determine if an institution was both timely and accurate in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information ? All HEERF Grantees). Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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 (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: 1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2022, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) III related to the Institutional Aid Portion and 3 reports for the Student Aid Portion. The Manager of Financial Planning, Budgeting & Analysis and Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each Institutional Aid and Student Aid report, respectively, utilizing the disbursement detail as well as other available support from the University?s information systems. The reports were then shared with management, who reviewed them and approved them via email, which was retained to show management?s authorization to post the reports. For the Institutional Aid report posted for the quarter ended December 31, 2021, the University inaccurately included lost revenue associated with fiscal year 2021, which would not have been allowable under the HEERF requirements. While the University was able to provide contractual services that were incurred in fiscal year 2022 to support the amounts expended, the report was not accurately prepared since ultimately the funds were not used to cover lost revenue. In addition, for the Student Aid report for the quarter ended December 31, 2021, we noted that the University did not include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Management?s review is not at the precision level necessary to ensure that the Institutional Aid report was accurately prepared or that the key line items related to the Student Aid report are included in the report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the University had eligible contractual service costs incurred (Institutional Aid report) and the key line item identified as missing does not have a monetary impact on the program (Student Aid report). Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer.
Finding No. 2022-001 Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that each report submission that is required to support spending under each of the Higher Education Emergency Relief Funds and other related funding programs has formal supporting documentation to evidence appropriate review of the report. This issue of how eligible students were determined and how the amounts distributed were determined was identified on the Q4 2021 Report due to the timing of the test work in the prior year Single Audit. This issue was corrected in the Q1 2022 Report and all available funding has been spent. The Assistant Vice President for Financial Aid has ensured that the total number of students eligible to receive a grant and the total number of students who receive grants is properly reviewed and documented. The Manager of Financial Planning, Budgeting and Analysis will ensure that all submitted Institutional Aid Reports are properly reconciled to actual expenditures rather than anticipated expenditures. The Q4 2021 Report was revised and reposted to reflect that expenditures were related to other costs rather than lost revenue. Each Student Aid Report and Institutional Aid Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented in the file. The submitted Reports will also be provided to the CFO, Vice President for Finance and Treasurer. Timing of Completion This corrective action was implemented in FY22 and FY23.
2021-001
Finding No. 2022-002 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). For those procurements supported by HEERF grant funds, auditors should determine if institutions sufficiently documented rationales and determinations in making any sole source awards during the time of national emergency due to the coronavirus. Exceptions from the competitive procurement requirements of the Uniform Guidance may be accepted if institutions have documented that the public exigency or emergency would not permit a delay, in accordance with 2 CFR section 200.320(f)(2). A circumstance that may influence this determination is the length of time between the procurements and the emergency at issue. Specifically, exceptions are more likely to be acceptable the closer the procurement occurred to the March 13, 2020 declaration of the national emergency. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University?s procurement policy for procurements over $10,000 is to either competitively bid it or document the sole source justification for why competitive bidding was not able to be completed. Based on our test work, for two of our seven selections, the University did not properly document its compliance with the procurement policy. For one selection, we noted that the University did not properly retain documentation for the competitive bidding, while for the other selection, the University did not properly document within the vendor?s procurement file that it was sole sourced due to the pandemic and needing the services in an expedited fashion as allowed per the HEERF requirements. Cause The documentation of procurement decisions was not properly retained to support the decisions made during the time period. Effect The University was not in compliance with their procurement policy. Questioned Costs There were no questioned costs identified as the University contracted with the respective parties in both cases and the costs were allowable under the HEERF requirements. Recommendation The University should strengthen its policies and practices to ensure that documentation is retained for all procurement decisions in order to support compliance with their procurement policy. Views of Responsible Official Management agrees with the recommendation. The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy.
Show full finding ▾Hide full finding ▴Finding No. 2022-002 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). For those procurements supported by HEERF grant funds, auditors should determine if institutions sufficiently documented rationales and determinations in making any sole source awards during the time of national emergency due to the coronavirus. Exceptions from the competitive procurement requirements of the Uniform Guidance may be accepted if institutions have documented that the public exigency or emergency would not permit a delay, in accordance with 2 CFR section 200.320(f)(2). A circumstance that may influence this determination is the length of time between the procurements and the emergency at issue. Specifically, exceptions are more likely to be acceptable the closer the procurement occurred to the March 13, 2020 declaration of the national emergency. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University?s procurement policy for procurements over $10,000 is to either competitively bid it or document the sole source justification for why competitive bidding was not able to be completed. Based on our test work, for two of our seven selections, the University did not properly document its compliance with the procurement policy. For one selection, we noted that the University did not properly retain documentation for the competitive bidding, while for the other selection, the University did not properly document within the vendor?s procurement file that it was sole sourced due to the pandemic and needing the services in an expedited fashion as allowed per the HEERF requirements. Cause The documentation of procurement decisions was not properly retained to support the decisions made during the time period. Effect The University was not in compliance with their procurement policy. Questioned Costs There were no questioned costs identified as the University contracted with the respective parties in both cases and the costs were allowable under the HEERF requirements. Recommendation The University should strengthen its policies and practices to ensure that documentation is retained for all procurement decisions in order to support compliance with their procurement policy. Views of Responsible Official Management agrees with the recommendation. The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy.
Finding No. 2022-002 Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy. Timing of Completion This corrective action has been implemented in FY23. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Brian Seabold, Director of Procurement (201) 216-8722.
Finding No. 2022-003 Research and Development Cluster: U.S. Department of Defense: Improved Ventilation of the Edematous Lung, Assistance Listing 93.838 (award number: 1R01HL113577-01A1) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-002). Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number. We selected twenty-five pieces of equipment and noted for one selection, the asset?s tag was not included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management did not properly ensure that the tag number was included within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Stevens Kuali Financial System. The Division of Finance has instituted an additional procedure to generate monthly asset tagging reports to address this issue and ensure that all assets are tagged in a timely manner. In addition, the Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System.
Show full finding ▾Hide full finding ▴Finding No. 2022-003 Research and Development Cluster: U.S. Department of Defense: Improved Ventilation of the Edematous Lung, Assistance Listing 93.838 (award number: 1R01HL113577-01A1) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2021-002). Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number. We selected twenty-five pieces of equipment and noted for one selection, the asset?s tag was not included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management did not properly ensure that the tag number was included within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Stevens Kuali Financial System. The Division of Finance has instituted an additional procedure to generate monthly asset tagging reports to address this issue and ensure that all assets are tagged in a timely manner. In addition, the Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System.
Finding No. 2022-003 Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Stevens Kuali Financial System. The Division of Finance has instituted an additional procedure to generate monthly asset tagging reports to address this issue and ensure that all assets are tagged in a timely manner. In addition, the Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System. Timing of Completion This corrective action has been implemented in FY23. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287, Jamie Houghtaling, Executive Director of Finance and Controller (201) 216-3348, Roger Moussallem, Senior Accountant (201) 216-3491 and Punam Patel, Staff Accountant (201) 216-8550.
2021-002
FAC accepted this audit on March 15, 2022 — management decision was due September 15, 2022.
Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion Assistance Listing 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2020-002). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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 (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion:1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2021, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) I and two reports for HEERF II related to the Student Aid Portion. Originally, the Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each report utilizing the disbursement detail as well as other available support from the University?s student information system. Then each report was discussed amongst a working group and reviewed by those individuals prior to posting it on the University?s website. Formal evidence was not retained to document management?s review and approval of the report prior to our finding in last year?s audit. To remediate the prior year finding, management implemented a change to their process to retain documentation related to management?s review and approval. Due to the timing of when the change was implemented, for one of our selections (report for the quarter ended September 30, 2020 for HEERF I), management could not provide evidence of review of the Report. However, based on the support provided, we noted that it was complete and accurate. Further, for the other report selected for test work (report for quarter ended June 30, 2021 for HEERF II), we noted that the estimated total number of students at the institution that are eligible to receive a grant (key line item #4) was not properly supported, nor did the University include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Prior to remediation of the prior year finding, management did not request formal documentation of the working group?s review of the Report. Further, management?s review is not to the precision level necessary to ensure that all the key line items are included in the report and that the amounts reported are accurate. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as key line items identified as incorrect or missing do not have a monetary impact on the program. Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate.
Show full finding ▾Hide full finding ▴Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion Assistance Listing 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: This is a repeat finding from the prior year single audit report (finding no. 2020-002). Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Criteria Quarterly Public Reporting for (a)(1) Student Aid Portion (Assistance Listings 84.425E) For CARES, beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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 (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Key Line Items ? The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion:1. Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 2. Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context During the year ended June 30, 2021, the University submitted 3 reports for Higher Education Emergency Relief Fund (HEERF) I and two reports for HEERF II related to the Student Aid Portion. Originally, the Assistant Vice President for Financial Aid and Undergraduate Admissions prepared each report utilizing the disbursement detail as well as other available support from the University?s student information system. Then each report was discussed amongst a working group and reviewed by those individuals prior to posting it on the University?s website. Formal evidence was not retained to document management?s review and approval of the report prior to our finding in last year?s audit. To remediate the prior year finding, management implemented a change to their process to retain documentation related to management?s review and approval. Due to the timing of when the change was implemented, for one of our selections (report for the quarter ended September 30, 2020 for HEERF I), management could not provide evidence of review of the Report. However, based on the support provided, we noted that it was complete and accurate. Further, for the other report selected for test work (report for quarter ended June 30, 2021 for HEERF II), we noted that the estimated total number of students at the institution that are eligible to receive a grant (key line item #4) was not properly supported, nor did the University include the method used to determine which students received a grant and the amount of such grant (key line item #6). Cause Prior to remediation of the prior year finding, management did not request formal documentation of the working group?s review of the Report. Further, management?s review is not to the precision level necessary to ensure that all the key line items are included in the report and that the amounts reported are accurate. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as key line items identified as incorrect or missing do not have a monetary impact on the program. Recommendation The University should strengthen its policies and practices to ensure that management?s review is precise enough to ensure that reports are complete and accurate.
Finding No. 2021 001 Compliance Requirement ? Reporting ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that each Report submitted as required to support spending under each of the Higher Education Emergency Relief Funds and other new funding has formal supporting documentation to evidence appropriate review of the Report. The Assistant Vice President for Enrollment Management will be responsible for preparing each Report as required for spending from each of the Higher Education Emergency Relief Funds. Each Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented. The submitted Reports will be provided to the CFO, Vice President for Finance and Treasurer. The Assistant Vice President for Enrollment Management will ensure that the total number of students eligible to receive a grant and the total number who receive a grant is properly reviewed and documented. Timing of Completion This corrective action has been implemented in FY22. Responsible for Corrective Action Louis Mayer, CFO, Vice President for Finance and Treasurer (201) 216-8761, Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Susan Gross, Assistant Vice President for Enrollment Management (201) 216-3400.
2020-002
Research and Development Cluster: U.S. Department of Defense: DURIP ? Laser Metal Deposition System for Additive Manufacturing and Corrosion Study of Metals, Assistance Listing 12.300 (award number: N00014-18-1-2268) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number.We selected twenty-five pieces of equipment and noted for two selections, the asset?s tag did not agree to the tag number included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management is not properly ensuring the accuracy of the tag number within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment.
Show full finding ▾Hide full finding ▴Research and Development Cluster: U.S. Department of Defense: DURIP ? Laser Metal Deposition System for Additive Manufacturing and Corrosion Study of Metals, Assistance Listing 12.300 (award number: N00014-18-1-2268) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Criteria Per guidance included in 2 CFR part 200.313, non-Federal entities other than States must follow regulations which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, the non-Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context Utilizing the listing of equipment additions provided by the Plant Fund manager, the Fixed Asset Specialist schedules a visit with the asset custodian to identify and tag the equipment. This process consists of affixing a barcode asset tag to the equipment. After tagging the equipment, the Fixed Asset Specialist will create an entry in Kuali. This entry will automatically generate a unique asset number in Kuali, for which, the Fixed Asset Specialist will then add all the required data related to that asset, including the tag number.We selected twenty-five pieces of equipment and noted for two selections, the asset?s tag did not agree to the tag number included in the Kuali Asset Management System, therefore the property records were not accurate. Cause Management is not properly ensuring the accuracy of the tag number within fixed asset management system. Effect The University may not be able to properly identify equipment funded with federal awards to ensure proper inventorying, safeguarding, and maintenance. Questioned Costs There are no questioned costs associated with this finding as the equipment was within the University?s possession. Recommendation The University should strengthen its policies and procedures related to maintaining property records and tagging equipment.
Finding No. 2021-002 Compliance Requirement ? Equipment and Real Property ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that each individual fixed asset is appropriately tagged and that the information for the asset reconciles to the information reported in the Kuali Financial System. The Division of Finance has instituted an additional procedure to address this issue. The Staff Accountant takes a picture of the asset tag for new assets which is attached to the supporting documentation in the Kuali Financial System. The Senior Accountant reviews the documentation for each asset and ensures that the appropriate asset tag is reflected in the Kuali Financial System. The Division of Finance engages an outside firm to conduct a complete physical inventory every two years. The Executive Director of Finance and Controller, the Senior Accountant and the Staff Accountant will ensure that all asset records are properly reflected in the Kuali Financial System. Timing of Completion This corrective action has been implemented in FY22. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287, Jamie Houghtaling, Executive Director of Finance and Controller (201) 216-3348, Roger Moussallem, Senior Accountant (201) 216-3491 and HJ Ahn, Staff Accountant (201) 216-3552.
FAC accepted this audit on May 31, 2021 — management decision was due December 1, 2021.
Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion CFDA 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Activities Allowed or Unallowed ? Significant Deficiency and Noncompliance Criteria For the (a)(1) Student Aid Portion (CFDA 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. Allowable expenditures must be ?for expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student?s cost of attendance, such as food, housing, course materials, technology, health care, and child care)? (CARES Act Section 18004(c)). As it relates to expenditures under the (a)(1) Student Aid Portion, auditors should determine (1) the institution had a documented plan to distribute funds to students, (2) that the institution did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, and (3) the institution expended the entirety of the Student Aid Portion grant on emergency financial aid grants to students and that the institution did not reimburse itself for any costs or expenses previously issued to students. Further, the non Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University received their ?Recipient Funding Certification and Agreement Emergency Financial Aid Grants to Students under the Coronavirus Aid, Relief, and Economic Security (CARES) Act? in April 2020. From then until their first disbursements in June 2020, management announced the receipt of funds and the process for how those funds would be awarded (i.e. through application) to the students on their website. Internally, management worked towards developing a process for how funds would be awarded, including established ranges for the various types of hardships that were included in the application (food insecurity, housing expenses, learning technology, loss of earnings, etc.) Each application was reviewed by the Assistant Vice President for Financial Aid and Undergraduate Admissions to determine initial award amounts. These amounts were discussed with a working group, further revisions were made to awards, and all awards were approved for disbursement. We selected forty awards, noting for seven students, the awards did not fall within the original established range. While management was able to articulate why certain students were awarded more than the ranges, they were unable to provide documented evidence to corroborate those judgments. Cause Management did not ensure that proper documentation was retained to ensure that the judgments made during the awarding process were appropriately documented. Effect The University is not in compliance with its documented policy. Questioned Costs There were no questioned costs identified as the awards for the hardships that the seven students applied for were allowable. Recommendation The University should strengthen its policies to ensure that all judgments made are documented within each student?s file to ensure that the verbal decisions made can be corroborated. Views of Responsible Officials Management agrees with the recommendation. The University has adopted a formal plan for the distribution of Higher Education Emergency Relief Funds II and III (HEERF II and HEERF III) and any other new funding that has been approved by the CFO, Vice President for Finance and Treasurer and Vice President for Enrollment Management and Student Affairs. The Assistant Vice President for Financial Aid and Undergraduate Admissions is responsible for administering the plan and documenting that all awards are supported with appropriate approvals. Any deviations from the approved plan will be documented with appropriate approvals. The Associate Vice President for Finance will ensure that all awards are appropriately documented and approved.
Show full finding ▾Hide full finding ▴Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion CFDA 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Activities Allowed or Unallowed ? Significant Deficiency and Noncompliance Criteria For the (a)(1) Student Aid Portion (CFDA 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. Allowable expenditures must be ?for expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student?s cost of attendance, such as food, housing, course materials, technology, health care, and child care)? (CARES Act Section 18004(c)). As it relates to expenditures under the (a)(1) Student Aid Portion, auditors should determine (1) the institution had a documented plan to distribute funds to students, (2) that the institution did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, and (3) the institution expended the entirety of the Student Aid Portion grant on emergency financial aid grants to students and that the institution did not reimburse itself for any costs or expenses previously issued to students. Further, the non Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University received their ?Recipient Funding Certification and Agreement Emergency Financial Aid Grants to Students under the Coronavirus Aid, Relief, and Economic Security (CARES) Act? in April 2020. From then until their first disbursements in June 2020, management announced the receipt of funds and the process for how those funds would be awarded (i.e. through application) to the students on their website. Internally, management worked towards developing a process for how funds would be awarded, including established ranges for the various types of hardships that were included in the application (food insecurity, housing expenses, learning technology, loss of earnings, etc.) Each application was reviewed by the Assistant Vice President for Financial Aid and Undergraduate Admissions to determine initial award amounts. These amounts were discussed with a working group, further revisions were made to awards, and all awards were approved for disbursement. We selected forty awards, noting for seven students, the awards did not fall within the original established range. While management was able to articulate why certain students were awarded more than the ranges, they were unable to provide documented evidence to corroborate those judgments. Cause Management did not ensure that proper documentation was retained to ensure that the judgments made during the awarding process were appropriately documented. Effect The University is not in compliance with its documented policy. Questioned Costs There were no questioned costs identified as the awards for the hardships that the seven students applied for were allowable. Recommendation The University should strengthen its policies to ensure that all judgments made are documented within each student?s file to ensure that the verbal decisions made can be corroborated. Views of Responsible Officials Management agrees with the recommendation. The University has adopted a formal plan for the distribution of Higher Education Emergency Relief Funds II and III (HEERF II and HEERF III) and any other new funding that has been approved by the CFO, Vice President for Finance and Treasurer and Vice President for Enrollment Management and Student Affairs. The Assistant Vice President for Financial Aid and Undergraduate Admissions is responsible for administering the plan and documenting that all awards are supported with appropriate approvals. Any deviations from the approved plan will be documented with appropriate approvals. The Associate Vice President for Finance will ensure that all awards are appropriately documented and approved.
Compliance Requirement ? Activities Allowed or Unallowed ? Significant Deficiency and Noncompliance Planned Corrective Action Management agrees with the recommendation. The University has adopted a formal plan for the distribution of Higher Education Emergency Relief Funds II and III (HEERF II and HEERF III) and any other new funding that has been approved by the CFO, Vice President for Finance and Treasurer and Vice President for Enrollment Management and Student Affairs. The Assistant Vice President for Financial Aid and Undergraduate Admissions is responsible for administering the plan and documenting that all awards are supported with appropriate approvals. Any deviations from the approved plan will be documented with appropriate approvals. The Associate Vice President for Finance will ensure that all awards are appropriately documented and approved. Timing of Completion A formal plan has been approved in FY21. The Associate Vice President for Finance and Assistant Vice President for Financial Aid and Undergraduate Admissions will ensure compliance in FY21. Responsible for Corrective Action Louis Mayer, CFO, Vice President for Finance and Treasurer (201) 216-8761, Marybeth Murphy, Vice President for Enrollment Management and Student Affairs (201) 216-8350, Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Susan Gross, Assistant Vice President for Financial Aid and Undergraduate Admissions (201) 216-3400.
Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion CFDA 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Reporting ? Significant Deficiency The non Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University was required to post the Student Aid Portion Quarterly Public Reporting (the Report) on its website after the first 30-day period and then every 45 days thereafter. As the University received their ?Recipient Funding Certification and Agreement Emergency Financial Aid Grants to Students under the Coronavirus Aid, Relief, and Economic Security (CARES) Act? in April 2020, two reports were required to be posted. The Assistant Vice President for Financial Aid and Undergraduate Admissions prepared the Report utilizing the disbursement detail as well as other available support from the University?s student information system. The Report was discussed amongst a working group and reviewed by those individuals prior to posting it on the University?s website. For our one selection, management could not provide evidence of review of the Report. However, based on the support provided, we noted that it was complete and accurate. Cause Management did not request formal documentation of the working group?s review of the Report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the report was complete and accurate. Recommendation The University should strengthen its policies and practices to ensure that formal documentation of review is retained for each report submitted. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each Report submitted as required to support spending under each of the Higher Education Emergency Relief Funds and other new funding has formal supporting documentation to evidence appropriate review of the Report. The Assistant Vice President for Financial Aid and Undergraduate Admissions will be responsible for preparing each Report as required for spending from each of the Higher Education Emergency Relief Funds. Each Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented. The submitted Reports will be provided to the CFO, Vice President for Finance and Treasurer and the Vice President for Enrollment Management and Student Affairs.
Show full finding ▾Hide full finding ▴Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion CFDA 84.425E (award number P425E201772) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Reporting ? Significant Deficiency The non Federal entity must establish and maintain an effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University was required to post the Student Aid Portion Quarterly Public Reporting (the Report) on its website after the first 30-day period and then every 45 days thereafter. As the University received their ?Recipient Funding Certification and Agreement Emergency Financial Aid Grants to Students under the Coronavirus Aid, Relief, and Economic Security (CARES) Act? in April 2020, two reports were required to be posted. The Assistant Vice President for Financial Aid and Undergraduate Admissions prepared the Report utilizing the disbursement detail as well as other available support from the University?s student information system. The Report was discussed amongst a working group and reviewed by those individuals prior to posting it on the University?s website. For our one selection, management could not provide evidence of review of the Report. However, based on the support provided, we noted that it was complete and accurate. Cause Management did not request formal documentation of the working group?s review of the Report. Effect The University may submit reports that are incomplete or inaccurate. Questioned Costs There were no questioned costs identified as the report was complete and accurate. Recommendation The University should strengthen its policies and practices to ensure that formal documentation of review is retained for each report submitted. Views of Responsible Official Management agrees with the recommendation. The University will ensure that each Report submitted as required to support spending under each of the Higher Education Emergency Relief Funds and other new funding has formal supporting documentation to evidence appropriate review of the Report. The Assistant Vice President for Financial Aid and Undergraduate Admissions will be responsible for preparing each Report as required for spending from each of the Higher Education Emergency Relief Funds. Each Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented. The submitted Reports will be provided to the CFO, Vice President for Finance and Treasurer and the Vice President for Enrollment Management and Student Affairs.
Compliance Requirement ? Reporting ? Significant Deficiency Planned Corrective Action Management agrees with the recommendation. The University will ensure that each Report submitted as required to support spending under each of the Higher Education Emergency Relief Funds and other new funding has formal supporting documentation to evidence appropriate review of the Report. The Assistant Vice President for Financial Aid and Undergraduate Admissions will be responsible for preparing each Report as required for spending from each of the Higher Education Emergency Relief Funds. Each Report will be reviewed and approved by the Associate Vice President for Finance. This review and approval will be documented. The submitted Reports will be provided to the CFO, Vice President for Finance and Treasurer and the Vice President for Enrollment Management and Student Affairs. Timing of Completion This corrective action has been implemented in FY21. Responsible for Corrective Action Louis Mayer, CFO, Vice President for Finance and Treasurer (201) 216-8761, Marybeth Murphy, Vice President for Enrollment Management and Student Affairs (201) 216-8350, Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Susan Gross, Assistant Vice President for Financial Aid and Undergraduate Admissions (201) 216-3400.
FAC accepted this audit on February 18, 2020 — management decision was due August 18, 2020.
FAC accepted this audit on February 27, 2019 — management decision was due August 27, 2019.
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2017-003
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2017-004
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2017-007
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
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2016-003
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2016-003
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2016-005
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2016-006
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2016-008
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FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
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2015-002
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