EIN: 364776757
UEI: H4CAHK2RD945
Audited by: CliftonLarsonAllen LLP
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 March 26, 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 26, 2026 (21 days from today).
What is a management decision? →FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient. Questioned costs: N/A Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued. Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: No Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per 34 CFR 668.164(l)(3), if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient. Questioned costs: N/A Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued. Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: No Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements. View of responsible official: The University agrees with the finding.
Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year. In addition, for the checks outstandings greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding Action in Response to Finding: The process during the current year has been to review the list of checks every 30 days but this has caused a failure in preventing checks from being returned after the 240 day mark. To rectify this, the Accountant II will review the comprehensive list on a monthly basis as well as checks that are in the future to ensure that we are not surpassing the 240 day mark by waiting for the next month to return. In addition, a report has been created to be delivered weekly that looks at all checks that are over 220 days old as a back up to ensure that no check is being missed and going over the 240 days requirement. Name of the Contact Person Responsible for Corrective Action: Megan Looney, Director of Student Financial Services Planned Completion Date for Corrective Action Plan: March 2025
As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days. Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days. Questioned costs: None Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program. Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. Repeat Finding: Yes Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Views of responsible officials: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days. Condition: As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days. Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days. Questioned costs: None Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program. Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. Repeat Finding: Yes Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Views of responsible officials: The University agrees with the finding.
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action in Response to Finding: Portland State University relies on a third party, National Student Clearinghouse, to report student enrollment status changes to the NSLDS. Fall 2023 and Winter 2024 enrollment certification files were provided to NSC for relay to NSLDS. Despite this, these enrollment files were never provided to NSLDS and as such the students status change, effective September 26, 2023, was not certified within the NSLDS until May 3, 2024. We are researching why these enrollment certification files were never provided to the NSLDS. Name of the Contact Person Responsible for Corrective Action: Nicolle DuPont, Associate Registrar Planned Completion Date for Corrective Action Plan: April 2025
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
The University made the first disbursement of proceeds of a Direct Subsidized Loan and a Direct Unsubsidized Loan to a student borrower on October 4, 2022 but conducted entrance counseling for the student borrower on February 21, 2024. The University’s processes and internal controls did not detect this instance of noncompliance. Context: We tested 45 students that were disbursed a Direct Subsidized Loan and/or a Direct Unsubsidized Loan during the fiscal year to determine the University’s compliance with counseling borrowers requirements as outlined by the Department of Education and noted one student was disbursed Direct Loans prior to the University ensuring that the student borrower had completed the required entrance counseling. Questioned costs: $7,500. Assistance Listing Number: 84.268 Cause: The student had completed course work at another school prior to enrollment at the University, however the University failed to ensure and/or retain documentation that the student had completed entrance counseling prior to disbursing the student proceeds of a Direct Subsidized and Direct Unsubsidized Loan. Effect: The University is not in compliance with counseling borrowers requirements. Repeat Finding: No. Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds. Views of responsible officials: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per 34 CFR 685.304(a)(1), a school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS Loan. Condition: The University made the first disbursement of proceeds of a Direct Subsidized Loan and a Direct Unsubsidized Loan to a student borrower on October 4, 2022 but conducted entrance counseling for the student borrower on February 21, 2024. The University’s processes and internal controls did not detect this instance of noncompliance. Context: We tested 45 students that were disbursed a Direct Subsidized Loan and/or a Direct Unsubsidized Loan during the fiscal year to determine the University’s compliance with counseling borrowers requirements as outlined by the Department of Education and noted one student was disbursed Direct Loans prior to the University ensuring that the student borrower had completed the required entrance counseling. Questioned costs: $7,500. Assistance Listing Number: 84.268 Cause: The student had completed course work at another school prior to enrollment at the University, however the University failed to ensure and/or retain documentation that the student had completed entrance counseling prior to disbursing the student proceeds of a Direct Subsidized and Direct Unsubsidized Loan. Effect: The University is not in compliance with counseling borrowers requirements. Repeat Finding: No. Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds. Views of responsible officials: The University agrees with the finding.
Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The error was caused by an abrupt resignation of loan processing staff and a lack of redundancy in critical processing areas. A staff member who was new to loan administration originated a loan then disbursed it to the student the moment it returned from COD. This rapid processing was in response to the student’s dire need for housing funding; however, the expedited process inadvertently circumvented the Banner system’s safeguards. This previously unknown issue has been resolved with the following systems updates: 1. Improved training and documentation 2. The previous system relied on RRAAREQ to prevent disbursement; however, the new system has a secondary and tertiary check that prevents disbursement. Both the entrance counseling tick box on RLADLOR and a positive indicator on the table that captures raw entrance counseling data (RPILECS) must align for a loan disbursement. Name of the contact person responsible for corrective action: Elijah Herr, Director of Financial Aid Planned completion date for corrective action plan: March 2024
As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS. Questioned costs: None. Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS. Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program. Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. Repeat finding: No Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Condition: As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS. Questioned costs: None. Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS. Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program. Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. Repeat finding: No Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: It appears that the erroneous enrollment status effective date reported is equal to the certification date for the enrollment file that was sent to the National Student Clearinghouse (NSC). We are researching how the certification date may have been substituted as the enrollment status effective date. Name of the contact person responsible for corrective action: Nicolle DuPont, Associate Registrar Planned completion date for corrective action plan: April 2024
The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2. Questioned costs: None. Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2. Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements. Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations. Repeat Finding: No Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course. Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2. Questioned costs: None. Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2. Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements. Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations. Repeat Finding: No Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University had already identified this weakness prior to the Single Audit. To address this weakness, Portland State University has implemented a robust Initiation of Attendance protocol that is required of every instructor. Faculty were informed of: 1) Federal regulations related to initiation of attendance. 2) The standards used for documenting academic engagement in an online environment. 3) The method by which the instructor positively indicates that an online student has academically engaged in the course. The University has provided written policies on its website and engaged in a vigorous communication plan with both faculty and students. Compliance with the new policy is monitored through weekly reporting, and instructors who have not documented the initiation of attendance are referred to their dean, chair or department head. Prior to any reduction in Title IV aid, students are notified of any missing documentation and encouraged to speak with their instructors immediately. Last, reconciliation reports are monitored by the financial aid office for discrepancies and any conflicting information is resolved by contacting the instructor. Name of the contact person responsible for corrective action: Elijah Herr, Director of Student Financial Aid, Cindy Baccar, Associate Vice Provost & University Registrar and Karenna Wait, Director of Enterprise Applications. Planned completion date for corrective action plan: September 2023
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that three out of eight vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the three vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: Yes Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The instances of missing evidence of screening for suspension and debarment during the single audit were related to sole source purchases on federal awards. The University will update its procedures to include screening for suspension and debarment at the time a request for sole source purchase is processed in PSU?s Contracting and Procurement Services (CAPS) office. Screening of the proposed sole source vendor will be performed by CAPS staff and the documentation of screening will be maintained in the procurement records. Name of the contact person responsible for corrective action: Karen Thomson, Director of Contracting and Procurement Services Planned completion date for corrective action plan: April 15, 2023
2021-003
We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University increase the time and effort certification process to be more timely Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: Sponsored Projects Administration (SPA) will decrease the amount of the time between the end of the semi-annual reporting periods and distribution of the Personnel Activity Reports (PARs). Deadlines for either certifying that the charges to sponsored awards reported on the PARs reasonably reflects the work activities for those projects or notifying SPA that salary adjustments are required. SPA will send reminder notices periodically prior to the deadline. After the deadline for the reporting period, past due notices will be sent repeatedly after the deadline until certification or notification of adjustments is received. SPA will establish a system for accepting change notifications and closely monitor the status of retroactive labor adjustments so that updated PARs can be issued, reviewed, and certified in a timely manner. Name of the contact person responsible for corrective action: Dawn Boatman, Assistant Vice President for Research Administration Planned completion date for corrective action plan: July 1, 2023
2021-004
We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 2 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University increase the time and effort certification process to be more timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: Sponsored Projects Administration (SPA) will decrease the amount of the time between the end of the semi-annual reporting periods and distribution of the Personnel Activity Reports (PARs). Deadlines for either certifying that the charges to sponsored awards reported on the PARs reasonably reflects the work activities for those projects or notifying SPA that salary adjustments are required. SPA will send reminder notices periodically prior to the deadline. After the deadline for the reporting period, past due notices will be sent repeatedly after the deadline until certification or notification of adjustments is received. SPA will establish a system for accepting change notifications and closely monitor the status of retroactive labor adjustments so that updated PARs can be issued, reviewed, and certified in a timely manner. Name of the contact person responsible for corrective action: Dawn Boatman, Assistant Vice President for Research Administration Planned completion date for corrective action plan: July 1, 2023
2021-005
While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? Institution has designated an individual to coordinate the information security program ? Institution has performed a risk assessment that addresses the three required noted in 16 CFR 314.4(b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? Institution has documented a safeguard for each risk identified above. Condition: While the University did conduct a formal risk assessment, the University did not document a safeguard for each risk identified during the risk assessment in compliance with the Act. Context: We noted during our review of the formal risk assessment performed by the University over various systems covered by the Act, the University did not formally document a safeguard for each risk identified. Cause: The University did not formally document a safeguard for each risk identified during its formal risk assessment Effect: Personal information could be vulnerable without identifying all potential risks and applying necessary safeguards. In addition, the University is not in compliance with all statutory and regulatory provisions as it pertains to safeguarding sensitive data. Repeat Finding: No Recommendation: We recommend that the University formally document a safeguard for each risk identified during its formal risk assessment to demonstrate compliance with the Act. Views of Responsible Officials: The University agrees with the finding.
Recommendation: We recommend that the University formally document safeguards for risks identified during its formal risk assessment to demonstrate compliance with the Act. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: PSU officials will take the additional steps to document the safeguards and internal control processes that mitigate the risks identified in the formal risk assessment PSU officials had performed for GLBA compliance requirements. Name of the contact person responsible for corrective action: Ryan Bass, Chief Information Officer, and Max Parmer, Senior Information Security Analyst Planned completion date for corrective action plan: June 30, 2023
FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.
A student was awarded this aid, but they did not demonstrate exceptional need since they had no need documented in a completed FAFSA nor did they complete an emergency aid application. Internal controls did not detect this instance of noncompliance. Context: We tested 60 students to determine the University?s compliance with HEERF requirements outlined by the Department of Education and noted one student did not have a completed FASFA or an emergency aid application in accordance with the University?s policy. Questioned costs: $500. ASSISTANCE LISTING Number: 84.425E Cause: The student had completed their FASFA, but later it was rejected. Due to the University?s automatic awarding system, the student was awarded in error. Effect: The student was awarded incorrectly as they were not eligible for the specific award. Repeat Finding: No. Recommendation: When implementing new funding streams that have eligibility requirements for distributions, we recommend implementing a control that would prevent distribution to participants that do not have all required documentation completed. This could be a review control or an automated information technology control. Views of responsible officials: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA Act) (P.L. 116-260), the student portion of funding requires that institutions prioritize students with exceptional need. Per the University?s policy established to distribute these funds to students, a student would demonstrate need as documented via their completed Free Application for Federal Student Aid (FAFSA) or via an emergency aid application. Condition: A student was awarded this aid, but they did not demonstrate exceptional need since they had no need documented in a completed FAFSA nor did they complete an emergency aid application. Internal controls did not detect this instance of noncompliance. Context: We tested 60 students to determine the University?s compliance with HEERF requirements outlined by the Department of Education and noted one student did not have a completed FASFA or an emergency aid application in accordance with the University?s policy. Questioned costs: $500. ASSISTANCE LISTING Number: 84.425E Cause: The student had completed their FASFA, but later it was rejected. Due to the University?s automatic awarding system, the student was awarded in error. Effect: The student was awarded incorrectly as they were not eligible for the specific award. Repeat Finding: No. Recommendation: When implementing new funding streams that have eligibility requirements for distributions, we recommend implementing a control that would prevent distribution to participants that do not have all required documentation completed. This could be a review control or an automated information technology control. Views of responsible officials: The University agrees with the finding.
Recommendation: When implementing new funding streams that have eligibility requirements for distributions, we recommend implementing a control that would prevent distribution to participants that do not have all required documentation completed. This could be a review control or an automated information technology control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: Department implemented a data check to ensure students with rejected ISIR records are not included in the automatically eligible for HEERF student award group. The particular student awarded due to a rejected ISIR record remained eligible for HEERF funds, no adjustment to the award is necessary. Name of the contact person responsible for corrective action: Amanda Bierbrauer, Associate Vice President for Enrollment Management & Student Finances. Planned completion date for corrective action plan: Completed August 2022.
For the public reporting on the Student Aid funding, three out of the four reports tested were not in compliance with the reporting requirements for the HEERF Student Aid Portion. Specifically, of the three instances of noncompliance noted, two could not be located on the University?s website and one of the reports did not report key, required items. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: During our testing of the four Student Quarterly HEERF reporting, two of the quarterly reports were not available for testing, as they were not retained on the University?s website. In addition, one of the four reports tested lacked key, required items, as documented in the Federal Register, Volume 85, No. 169 & Volume 86, No. 91 - Department of Education, on the University?s website. The missing key items included: (1) An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used the applicable amount of funds designated under CARES and CRRSAA. (2) The total amount of funds that the institution will receive or has received from the Department pursuant to the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under the CARES and CRRSAA. (3) The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under CARES and CRRSAA. Cause: The University represented they did have the key items available on the website at the time each report was originally due; however, historical data was overwritten with each new student quarterly report, as the key items were originally embedded on the University?s website as code versus being a separate non-overwritable report. Effect: The University was not in compliance with HEERF Student Aid Portion reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure historical reports remain available as separate non-overwritable reports. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per the Coronavirus Aid, Relief, and Economic Security Act, 2020 (CARES Act) (P.L. 116-136,134, Stat. 281) and per the CRRSAA Act, 2021 (P.L. 116-260), institutions receiving funds must submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from HEERF funding. This includes three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: For the public reporting on the Student Aid funding, three out of the four reports tested were not in compliance with the reporting requirements for the HEERF Student Aid Portion. Specifically, of the three instances of noncompliance noted, two could not be located on the University?s website and one of the reports did not report key, required items. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: During our testing of the four Student Quarterly HEERF reporting, two of the quarterly reports were not available for testing, as they were not retained on the University?s website. In addition, one of the four reports tested lacked key, required items, as documented in the Federal Register, Volume 85, No. 169 & Volume 86, No. 91 - Department of Education, on the University?s website. The missing key items included: (1) An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used the applicable amount of funds designated under CARES and CRRSAA. (2) The total amount of funds that the institution will receive or has received from the Department pursuant to the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under the CARES and CRRSAA. (3) The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under CARES and CRRSAA. Cause: The University represented they did have the key items available on the website at the time each report was originally due; however, historical data was overwritten with each new student quarterly report, as the key items were originally embedded on the University?s website as code versus being a separate non-overwritable report. Effect: The University was not in compliance with HEERF Student Aid Portion reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure historical reports remain available as separate non-overwritable reports. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University review their reporting policies and procedures to ensure historical reports remain available as separate non-overwritable reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: All historical quarterly reports have been posted to the website, including reports that reflect no activity during the quarter. Name of the contact person responsible for corrective action: Amanda Bierbrauer, Associate Vice President for Enrollment Management & Student Finances. Planned completion date for corrective action plan: Completed August 2022.
We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that two out of nine vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the two vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: No Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished date through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to transaction. Condition: We noted that the University does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted that two out of nine vendors selected for testing were not verified that they had not been suspended or debarred prior to the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but this was subsequent to the transaction date. Questioned costs: None Context: The University does have a policy and procedure to verify a vendor's suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University stated they reviewed the active record within SAM.gov, but did not keep a copy of the review or other evidence of the review for the two vendors. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat finding: No Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding:. The University will update the controls over suspension and debarment for procurement transactions in order to document compliance by including a required certification regarding debarment and suspension in responses to Requests for Quotations and Requests for Proposals. Name of the contact person responsible for corrective action: Dawn Boatman, Assistant Vice President for Research Administration Planned completion date for corrective action plan: Immediately
We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s Time and Effort is documented, at the start of each fiscal year in the initial time and effort budget and at the end of the year, through a certification of actual time and effort. For 21 of the 40 tested, the certification of time and effort occurred from 124 days to 584 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: No Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s Time and Effort is documented, at the start of each fiscal year in the initial time and effort budget and at the end of the year, through a certification of actual time and effort. For 21 of the 40 tested, the certification of time and effort occurred from 124 days to 584 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: No Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University increase the time and effort certification process to be more timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding:. The University uses after-the-fact activity reports to document personnel expenses on Federal awards on a semi-annual basis. The significant delay in certification of the reports that document the accuracy of charges for effort performed on sponsored projects during fiscal year 2021 was due to delayed distribution of these reports to salaried individuals and delays in adjustments to correct salary charges identified during report review. The delays were due to severe staffing shortages in Sponsored Projects Administration, exacerbated by furloughs and complications of working during the height of the COVID-19 pandemic. The University has returned to its regular process of distributing and collecting the reports in a timely manner. Name of the contact person responsible for corrective action: Dawn Boatman, Assistant Vice President for Research Administration Planned completion date for corrective action plan: Immediately
We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s Time and Effort is documented, at the start of each fiscal year in the initial time and effort budget and at the end of the year, through a certification of actual time and effort. For 29 of the 40 tested the certification of time and effort occurred from 265 to 544 days after the quarterly end date Cause: The University stated they The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: No Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s Time and Effort is documented, however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s Time and Effort is documented, at the start of each fiscal year in the initial time and effort budget and at the end of the year, through a certification of actual time and effort. For 29 of the 40 tested the certification of time and effort occurred from 265 to 544 days after the quarterly end date Cause: The University stated they The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: No Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Recommendation: We recommend that the University increase the time and effort certification process to be more timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding:. The University uses after-the-fact activity reports to document personnel expenses on Federal awards on a semi-annual basis. The significant delay in certification of the reports that document the accuracy of charges for effort performed on sponsored projects during fiscal year 2021 was due to delayed distribution of these reports to salaried individuals and delays in adjustments to correct salary charges identified during report review. The delays were due to severe staffing shortages in Sponsored Projects Administration, exacerbated by furloughs and complications of working during the height of the COVID-19 pandemic. The University has returned to its regular process of distributing and collecting the reports in a timely manner. Name of the contact person responsible for corrective action: Dawn Boatman, Assistant Vice President for Research Administration Planned completion date for corrective action plan: Immediately
Based on review of invoice support, it is noted that $246 of expenses were unrelated to defraying expenses associated with coronavirus, but rather included other medical supply items such as a splint, braces, crutches, bandages, crutches, and hot packs. Internal controls did not detect these instances of noncompliance. Context: We tested 40 expenditures to determine the University?s compliance with HEERF Institutional Aid requirements outlined by the Department of Education and noted two expenditures included other non-coronavirus related medical supply purchases. Questioned costs: $246. ASSISTANCE LISTING Number: 84.425F Cause: Lack of proper review to determine if expenses were allowable under the grant agreement. Effect: The University was not in compliance with HEERF Institutional Aid Portion expenditure requirements. Repeat Finding: No. Recommendation: We recommend implementing a control to ensure individual invoice items are properly allocated to the appropriate grant for reimbursement. Views of responsible officials: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Per the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA Section 314(c)(1-3); ARP Section 2003), expenses after December 27, 2020 may be used to defray expenses associated with coronavirus (including reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll) and to make additional financial grants to students. Condition: Based on review of invoice support, it is noted that $246 of expenses were unrelated to defraying expenses associated with coronavirus, but rather included other medical supply items such as a splint, braces, crutches, bandages, crutches, and hot packs. Internal controls did not detect these instances of noncompliance. Context: We tested 40 expenditures to determine the University?s compliance with HEERF Institutional Aid requirements outlined by the Department of Education and noted two expenditures included other non-coronavirus related medical supply purchases. Questioned costs: $246. ASSISTANCE LISTING Number: 84.425F Cause: Lack of proper review to determine if expenses were allowable under the grant agreement. Effect: The University was not in compliance with HEERF Institutional Aid Portion expenditure requirements. Repeat Finding: No. Recommendation: We recommend implementing a control to ensure individual invoice items are properly allocated to the appropriate grant for reimbursement. Views of responsible officials: The University agrees with the finding.
Recommendation: We recommend implementing a control to ensure individual invoice items are properly allocated to the appropriate funding stream. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: We noted that this finding was specific to Procurement Card Transactions that were reclassified to the grant after being charged to a University Department fund. These transactions will now require support to be sent to the Controller?s office for review before a draw down of funds occur. Name of the contact person responsible for corrective action: Jason Abbott, Controller Planned completion date for corrective action plan: Implementation will begin October 1, 2022
FAC accepted this audit on July 21, 2021 — management decision was due January 21, 2022.
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
During our testing of a sample of 40 students who had a change in enrollment status during the period under audit, we noted that one student?s social security number provided as a part of the submission roster was rejected by the National Student Clearinghouse (NSC), returned to the University in the transmission error report and was not resolved in a timely manner. We also noted two instances in which the student?s enrollment status were not reported properly within the required timeframe to the NSLDS. Questioned costs: None. Context: Out of a statistically valid sample of 40 students selected for testing for the requirement noted above, we noted three exceptions as described above. Cause: One of the three errors was not corrected in a timely manner due to the Office of the Registrar not reviewing the specific transmission error report provided by the NSC. Two of the three errors were not reported correctly due to the University not having proper internal controls in place to ensure issues were discovered prior to uploading rosters to the NSC who then submits required information to the NSLDS. Effect: The NSLDS was not updated with the student?s enrollment information, which can cause over-awarding should the student transfer to another institution or the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: We recommend that the University enhance its procedures for monitoring and correcting the transmission error files that are returned by the NSC to ensure that corrections are made in a timely manner. We also recommend that the University implement monitoring procedures to ensure student status information is accurately provided to the NSC for the submission to the NSLDS within the required timeframes. Views of Responsible Officials and Management?s Response: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309, requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status includes an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing of a sample of 40 students who had a change in enrollment status during the period under audit, we noted that one student?s social security number provided as a part of the submission roster was rejected by the National Student Clearinghouse (NSC), returned to the University in the transmission error report and was not resolved in a timely manner. We also noted two instances in which the student?s enrollment status were not reported properly within the required timeframe to the NSLDS. Questioned costs: None. Context: Out of a statistically valid sample of 40 students selected for testing for the requirement noted above, we noted three exceptions as described above. Cause: One of the three errors was not corrected in a timely manner due to the Office of the Registrar not reviewing the specific transmission error report provided by the NSC. Two of the three errors were not reported correctly due to the University not having proper internal controls in place to ensure issues were discovered prior to uploading rosters to the NSC who then submits required information to the NSLDS. Effect: The NSLDS was not updated with the student?s enrollment information, which can cause over-awarding should the student transfer to another institution or the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: We recommend that the University enhance its procedures for monitoring and correcting the transmission error files that are returned by the NSC to ensure that corrections are made in a timely manner. We also recommend that the University implement monitoring procedures to ensure student status information is accurately provided to the NSC for the submission to the NSLDS within the required timeframes. Views of Responsible Officials and Management?s Response: The University agrees with the finding.
Recommendation: We recommend that the University enhance its procedures for monitoring and correcting the transmission error files that are returned by the NSC to ensure that corrections are made in a timely manner. We also recommend that the University implement monitoring procedures to ensure student status information is accurately provided to the NSC for the submission to the NSLDS within the required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed the various Reject Record Error reports that help us identify the records rejected for mis-matched SSNs and will prioritize resolving these records. We reviewed the listing of enrollment statuses for federal financial aid purposes and updated the listing to include Three-Quarter Time for Graduate students. We have identified an error report that allows us to review students in graduated status who do not have a ?G ? graduated? record listed in the NSC. Name(s) of the contact person(s) responsible for corrective action: Nicolle DuPont, Associate Registrar Planned completion date for corrective action plan: February 1, 2020
During our testing over compliance related to verification, we noted that the University did not adhere to verification regulations as follows: - One student was disbursed aid despite not completing the verification procedures. - Four students were not required to submit proper documentation for income originally reported. Questioned costs: $12,368 of aid was disbursed to the student who did not complete the verification procedures. $51,865 was disbursed to the four students who were not required to submit proper documentation to support income originally reported. Context: We tested a statistically valid sample of 40 verifications occurring during the fiscal year. Of the 40 verifications tested, we noted five instances where controls failed to prevent disbursement of aid when the verification process was not complete or in which the student was not required to return the proper documentation by the University. Cause: The University did not require students to submit proper documentation for income verification relating to non-filing household members. In addition, the University did not have proper controls in place to ensure it met verification compliance requirements. Effect: The University originated and disbursed grants and loans to students without adhering to verification regulations. Repeat Finding: Yes, prior year finding 2018-003. Recommendation: We recommend that the University provide training to staff to ensure that they are in compliance with the various verification requirements and implement automated controls that require verification be completed on all selected students. Views of Responsible Officials and Management?s Response: The University agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: 2 CFR 200.303 requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. Per 2 CFR 668.51 through 668.61, the institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition: During our testing over compliance related to verification, we noted that the University did not adhere to verification regulations as follows: - One student was disbursed aid despite not completing the verification procedures. - Four students were not required to submit proper documentation for income originally reported. Questioned costs: $12,368 of aid was disbursed to the student who did not complete the verification procedures. $51,865 was disbursed to the four students who were not required to submit proper documentation to support income originally reported. Context: We tested a statistically valid sample of 40 verifications occurring during the fiscal year. Of the 40 verifications tested, we noted five instances where controls failed to prevent disbursement of aid when the verification process was not complete or in which the student was not required to return the proper documentation by the University. Cause: The University did not require students to submit proper documentation for income verification relating to non-filing household members. In addition, the University did not have proper controls in place to ensure it met verification compliance requirements. Effect: The University originated and disbursed grants and loans to students without adhering to verification regulations. Repeat Finding: Yes, prior year finding 2018-003. Recommendation: We recommend that the University provide training to staff to ensure that they are in compliance with the various verification requirements and implement automated controls that require verification be completed on all selected students. Views of Responsible Officials and Management?s Response: The University agrees with the finding.
Recommendation: We recommend that the University provide training to staff to ensure that they are in compliance with the various verification requirements and implement automated controls that require verification be completed on all selected students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Responsible employees have received additional training and subsequent verifications have been reviewed. Regular training for all staff performing verifications has been implemented and random samples of files will be regularly reviewed as part of our quality assurance plan. Further, Financial Aid will consult with OIT to see if any automated audit reports can be created to help catch errors. Name(s) of the contact person(s) responsible for corrective action: Amanda Bierbrauer, Associate Vice President of Enrollment Management & Student Finances Planned completion date for corrective action plan: February 1, 2020
2018-003
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-002
GSA_MIGRATION
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GSA_MIGRATION
2017-001
FAC accepted this audit on March 22, 2018 — management decision was due September 22, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2016-002
FAC accepted this audit on March 22, 2017 — management decision was due September 22, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-003
GSA_MIGRATION
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GSA_MIGRATION
2015-002
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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