EIN: 310732831
UEI: NPT2UNTNHJZ1
Audit also covers EIN: 161704454
Audited by: Forvis Mazars
Cognizant agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 19, 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 August 19, 2026 (16 days ago).
What is a management decision? →Federal Program - Research and Development Cluster Assistance Listing Numbers - Various Federal Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement – Subrecipient Monitoring - Management is responsible for verifying that subrecipients expected to be audited as required by CFR part 200, subpart F, met this requirement. (2 CFR 200.332(g)) Condition - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed during the year. Cause - Turnover of University personnel responsible for subrecipient monitoring. Questioned Costs - There were no questioned costs as a result of this finding. Effect - While management did follow established controls to determine whether subrecipients used the Federal awards for authorized purposes and complied with Federal statutes, regulations and the terms and conditions of the sub award, by not confirming whether subrecipients had received required audits, management may not become aware of subrecipients with audit findings. Context - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed for all ten subrecipients during the year. Identification as a Repeat Finding - No. Recommendation - We recommend management bring subrecipient audit documentation current and complete training with responsible individuals to ensure future compliance.
Show full finding ▾Hide full finding ▴Federal Program - Research and Development Cluster Assistance Listing Numbers - Various Federal Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement – Subrecipient Monitoring - Management is responsible for verifying that subrecipients expected to be audited as required by CFR part 200, subpart F, met this requirement. (2 CFR 200.332(g)) Condition - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed during the year. Cause - Turnover of University personnel responsible for subrecipient monitoring. Questioned Costs - There were no questioned costs as a result of this finding. Effect - While management did follow established controls to determine whether subrecipients used the Federal awards for authorized purposes and complied with Federal statutes, regulations and the terms and conditions of the sub award, by not confirming whether subrecipients had received required audits, management may not become aware of subrecipients with audit findings. Context - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed for all ten subrecipients during the year. Identification as a Repeat Finding - No. Recommendation - We recommend management bring subrecipient audit documentation current and complete training with responsible individuals to ensure future compliance.
The University concurs that annual subrecipient monitoring is required under Uniform Guidance and the OMB Compliance Supplement. Subrecipient monitoring activities are operationally performed within Research and Sponsored Programs (RSP). The lack of documented monitoring during the period under audit is attributable to changes in staffing and workflows within RSP, which resulted in a lapse in the consistent execution and documentation of established monitoring procedures. Upon identification of this issue, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP and initiated corrective actions to ensure the subrecipient monitoring requirement will be consistently met going forward. The OoC is working with RSP to reestablish and formalize monitoring procedures and to ensure appropriate staffing resources and review processes are in place. As part of the corrective action plan, the University will complete monitoring in FY2026 for subrecipients with audited financial statements for Fiscal Year 2025 and Calendar Year 2025, where practicable. In addition, as a retrospective measure, the University will review available subrecipient audit reports for Fiscal Year 2024 to confirm whether monitoring requirements were met and to document the results of that review. Further, the OoC and RSP will collaboratively define and document roles and responsibilities for obtaining, reviewing, and retaining subrecipient audit reports on an annual basis. These actions are focused on strengthening annual audit verification procedures for subrecipients, ensure ongoing compliance with Uniform Guidance requirements, and prevent recurrence of the condition.
Federal Program - Research and Development Cluster Assistance Listing Numbers - Various Federal Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement – Period of Performance – Costs must be incurred during the approved budget period. (2 CFR 200.403(h)) Condition - Management reported instances where costs not incurred during the approved budget period were charged to the grant. Cause - Turnover of University personnel responsible. Questioned Costs – We identified $498 in questioned costs, calculated per vendor invoice, as a result of our audit procedures performed surrounding period of performance. The grant programs and amounts improperly charged identified during testing were: • Assistance Listing Number: 16.838 o Award Number: 15PBJA-21-GG-04493-COAP; Linkage to Hope Project - $479 • Assistance Listing Number: 12.800 o Award Number: FA8650-20-F-5234; Direct Integrated/Computational/Testing and Onsite Research (DICTATOR) - $19 Effect – While the University has established controls to detect costs recorded that had been incurred outside of the approved period, by not fully following these control guidelines, costs that would be unallowable under 2 CFR 200.403(h) may be applied incorrectly. Context - Management reported instances where costs not incurred during the approved budget period had been recorded. From a sample of 5 grants (population of 44 grants), two grants had expenditures recorded to the grant for costs that had not been incurred within the approved budget period. This sample was not, and was not intended to be, a statistically valid sample. Identification as a Repeat Finding - No. Recommendation - We recommend management consult with the grantor to discuss whether the questioned costs should be refunded and complete training with responsible individuals to ensure future compliance.
Show full finding ▾Hide full finding ▴Federal Program - Research and Development Cluster Assistance Listing Numbers - Various Federal Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement – Period of Performance – Costs must be incurred during the approved budget period. (2 CFR 200.403(h)) Condition - Management reported instances where costs not incurred during the approved budget period were charged to the grant. Cause - Turnover of University personnel responsible. Questioned Costs – We identified $498 in questioned costs, calculated per vendor invoice, as a result of our audit procedures performed surrounding period of performance. The grant programs and amounts improperly charged identified during testing were: • Assistance Listing Number: 16.838 o Award Number: 15PBJA-21-GG-04493-COAP; Linkage to Hope Project - $479 • Assistance Listing Number: 12.800 o Award Number: FA8650-20-F-5234; Direct Integrated/Computational/Testing and Onsite Research (DICTATOR) - $19 Effect – While the University has established controls to detect costs recorded that had been incurred outside of the approved period, by not fully following these control guidelines, costs that would be unallowable under 2 CFR 200.403(h) may be applied incorrectly. Context - Management reported instances where costs not incurred during the approved budget period had been recorded. From a sample of 5 grants (population of 44 grants), two grants had expenditures recorded to the grant for costs that had not been incurred within the approved budget period. This sample was not, and was not intended to be, a statistically valid sample. Identification as a Repeat Finding - No. Recommendation - We recommend management consult with the grantor to discuss whether the questioned costs should be refunded and complete training with responsible individuals to ensure future compliance.
The University concurs that costs charged to federal awards must be incurred within the approved period of performance in accordance with Uniform Guidance and the OMB Compliance Supplement. The instances identified during the audit were attributable to personnel turnover within Research and Sponsored Programs (RSP), which resulted in isolated lapses in the consistent application of existing period of performance review procedures during the period under audit. Upon identification of these items, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP to address the questioned costs. RSP initiated the process to remove the costs from the affected grants and, where applicable, to consult with the sponsor and refund the disallowed amounts. As part of the corrective action plan, RSP will reinforce existing period of performance controls through targeted communication and training with responsible personnel involved in grant administration and expenditure processing. RSP will continue to perform pre- and post-expenditure reviews to ensure that costs charged to federal awards are incurred within the approved budget period and are appropriately documented. These actions are focused on reinforcing the timing review of expenditures charged to federal awards and are intended to ensure ongoing compliance with Uniform Guidance requirements and to prevent recurrence of the condition.
FAC accepted this audit on November 14, 2024 — management decision was due May 14, 2025.
FAC accepted this audit on December 19, 2023 — management decision was due June 19, 2024.
FAC accepted this audit on December 14, 2022 — management decision was due June 14, 2023.
FAC accepted this audit on December 14, 2021 — management decision was due June 14, 2022.
FAC accepted this audit on March 2, 2021 — management decision was due September 2, 2021.
FAC accepted this audit on March 8, 2020 — management decision was due September 8, 2020.
Federal Program - U.S Department of Education - Student Financial Assistance Cluster CFDA No. 84.268, Federal Direct Student Loan Program CFDA No. 84.063, Federal Pell Grant Program Program Year 2018-2019 Award Numbers - P268K, P063P Criteria or Specific Requirement - Special Tests and Provisions - Management is responsible for reporting changes in student status to the National Student Loan Data System for Students (NSLDS). Changes in enrollment must be reported within 30 days. However, if a roster file is expected within 60 days, management may report the status changes via that roster. (34 CFR 685.309b) Condition - Changes in status for four students were not accurately and/or timely reported to NSLDS. Specifically, status changes for four students were not reported to the NSLDS within 60 days and therefore, did not reflect the correct status timely. Questioned Costs - There were no questioned costs as a result of this finding. Context - From a sample of 40 student status changes tested (population of 2,612 student status changes), the change in status for four students was not reported accurately and/or timely to the NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Effect - Timely and accurate reporting of status changes is important because it is used to determine if the student is still considered enrolled, must be moved into repayment, or is eligible for an in-school deferment. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds Cause - The primary cause for the reporting issues related to students enrolled in dualdegree programs. Specifically, the completion of the first degree of the dual program was not being reported timely to NSLDS as the University?s system was still showing the student as actively enrolled. Identification as a Repeat Finding - No. Recommendation - We recommend management report the completion of each degree in dual programs timely. Once the University concludes the student has officially completed each degree within a dual program, report the change in status to ensure timely and accurate reporting to NSC and NSLDS.
Show full finding ▾Hide full finding ▴Federal Program - U.S Department of Education - Student Financial Assistance Cluster CFDA No. 84.268, Federal Direct Student Loan Program CFDA No. 84.063, Federal Pell Grant Program Program Year 2018-2019 Award Numbers - P268K, P063P Criteria or Specific Requirement - Special Tests and Provisions - Management is responsible for reporting changes in student status to the National Student Loan Data System for Students (NSLDS). Changes in enrollment must be reported within 30 days. However, if a roster file is expected within 60 days, management may report the status changes via that roster. (34 CFR 685.309b) Condition - Changes in status for four students were not accurately and/or timely reported to NSLDS. Specifically, status changes for four students were not reported to the NSLDS within 60 days and therefore, did not reflect the correct status timely. Questioned Costs - There were no questioned costs as a result of this finding. Context - From a sample of 40 student status changes tested (population of 2,612 student status changes), the change in status for four students was not reported accurately and/or timely to the NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Effect - Timely and accurate reporting of status changes is important because it is used to determine if the student is still considered enrolled, must be moved into repayment, or is eligible for an in-school deferment. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds Cause - The primary cause for the reporting issues related to students enrolled in dualdegree programs. Specifically, the completion of the first degree of the dual program was not being reported timely to NSLDS as the University?s system was still showing the student as actively enrolled. Identification as a Repeat Finding - No. Recommendation - We recommend management report the completion of each degree in dual programs timely. Once the University concludes the student has officially completed each degree within a dual program, report the change in status to ensure timely and accurate reporting to NSC and NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The Office of the Registrar (Registrar) concurs with the auditors that the four students identified during this audit were incorrectly reported to the NSLDS. These errors resulted because: ? The students? master?s programs were never ended in the Banner student registration module. ? Then Banner enrollment status overwrote the manual changes reported to the Clearinghouse and changed the students? status to full-time. ? The error was identified by the Office of the Registrar and manually corrected with the Clearinghouse on May 24th, which reported to NSLDS on June 1st. The changes were loaded by NSLDS on June 5th, 61 days after the graduation date. The Registrar has examined these issues and has determined the following corrective action. The Registrar will: ? Continue to educate various constituents who award degrees the importance of updating student information in Banner. ? Update the enrollment reporting schedule to take the manually graduated status process into consideration, so that enrollment reports submitted to the Clearinghouse are not submitted until all manual updates have been submitted to NSLDS.
Federal Program - Research and Development Cluster CFDA Number - Various Sponsoring Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement - Allowable Costs/Cost Principles - Management is responsible for ensuring charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed, including support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (2 CFR 200.430(i)) Condition - Management reported that established time and effort certification procedures had not been completed during the year. Questioned Costs - There were no questioned costs as a result of this finding. Context - Management reported that time and effort certification procedures had not been completed for all sponsored projects during the year. From a sample of 25 expenses tested, including 6 payroll transactions (population of 2,018 expenses), time and effort certification had not been obtained for the 6 payroll transactions tested. Our sampling method was not, and was not intended to be, statistically valid. Effect - While management did follow established controls to review actual versus budgeted time on sponsored projects, errors in allocation of salaries and wages on specific grants could occur. Cause - Turnover of University personnel responsible for collecting certifications. Identification as a Repeat Finding - No. Recommendation - We recommend management bring time and effort certifications current and complete training with responsible individuals to ensure future compliance.
Show full finding ▾Hide full finding ▴Federal Program - Research and Development Cluster CFDA Number - Various Sponsoring Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement - Allowable Costs/Cost Principles - Management is responsible for ensuring charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed, including support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (2 CFR 200.430(i)) Condition - Management reported that established time and effort certification procedures had not been completed during the year. Questioned Costs - There were no questioned costs as a result of this finding. Context - Management reported that time and effort certification procedures had not been completed for all sponsored projects during the year. From a sample of 25 expenses tested, including 6 payroll transactions (population of 2,018 expenses), time and effort certification had not been obtained for the 6 payroll transactions tested. Our sampling method was not, and was not intended to be, statistically valid. Effect - While management did follow established controls to review actual versus budgeted time on sponsored projects, errors in allocation of salaries and wages on specific grants could occur. Cause - Turnover of University personnel responsible for collecting certifications. Identification as a Repeat Finding - No. Recommendation - We recommend management bring time and effort certifications current and complete training with responsible individuals to ensure future compliance.
Views of Responsible Officials and Planned Corrective Actions - The Office of the Controller (OoC) concurs that effort reporting and training must be made current as a requirement of Uniform Guidance. The lag in Effort Certifications appears to be attributable to leadership turnover within the OoC, resulting in a lapse of monitoring controls. Since notifying the auditors of the lapse in control, the OoC has assembled a team consisting of members from Research and Sponsored Programs (RSP), Research Compliance, and the Office of the Controller. The team will focus on an action plan to bring effort certifications current during fiscal year 2020. Key attributes of the plan include: ? Defining of the various levels of reviewer and certifier; ? Updating earnings codes for inclusion in institutional based salaries; ? Developing training for certifiers and their delegates; ? Determining a timeline and the proper controls for monitoring the process prospectively. In addition, the OoC will work with RSP and Research Compliance to determine the best practice for ownership and monitoring of the Effort Certification process.
FAC accepted this audit on December 16, 2018 — management decision was due June 16, 2019.
FAC accepted this audit on January 27, 2018 — management decision was due July 27, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on January 17, 2017 — management decision was due July 17, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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