GRAND VALLEY STATE UNIVERSITYHigher Education

Assistance Listing, Federal Agency, and Program Name 84.268 U.S. Department of Education, Federal Direct Student Loans; 84.038 U.S. Department of Education, Federal Perkins Loan Program; 84.063 Federal Pell Grant Program Pass through Entity None Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria The University has 60 days from the date of the University determines an enrollment status change to report to the National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309) Condition Of the 25 students selected for enrollment reporting, the University did not update the student enrollment information for four students accurately. Questioned Costs None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed None Context The University's process for submitting the enrollment status change includes using the National Student Clearing House, a third party, which ultimately submits the status changes to NSLDS on behalf of the University. The submission the sample selection was submitted was overridden and the entire batch was not transmitted to NSLDS. Cause and Effect The University did not have formal procedures to verify that the National Student Clearing House has accurately reported the data provided by the University to NSLDS resulting in inappropriate enrollment status reported to NSLDS. Recommendation The University should consider implementing a process to review all submissions to NSLDS to ensure the required reporting elements are submitted by the use of the third party. Views of Responsible Officials and Corrective Action Plan Upon learning of these errors during the audit, the University conducted a review of all 2024–2025 records to ensure that all other reports were accurate. The University uses a third party provider to perform these actions and while the University is responsible for verification, concrete controls have been put in place. The University will examine and compare NSLDS data three times per year to identify and resolve any inconsistencies in a timely manner. Additionally, the third party provider has indicated it is reviewing its internal practices to help ensure similar reporting issues do not occur in the future.

Assistance Listing, Federal Agency, and Program Name 21.027 COVID 19 Coronavirus State and Local Fiscal Recovery Funds and 84.215 Innovative Approaches to Literacy Federal Award Identification Number and Year Coronavirus State and Local Fiscal Recovery Funds SLFRP1027 Innovative Approaches to Literacy S215K230129 Pass through Entity 21.027 Michigan Strategic Fund; 20 Fathoms; Lean Rocket Lab; Talent First Inc; Lansing Economic Area Partnership; Michigan Economic Development Corporation 84.215 N/A Finding Type Significant Deficiency Repeat Finding No Criteria Recipients of federal awards are required to follow their internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Per the University policy, all grant funded purchases in excess of $25,000 should be verified using SAM.gov the supplier is not suspended or debarred and the results should be retained in the purchase requisition. As Uniform Guidance restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal award (CFR 200.214). Condition In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Coronavirus State and Local Fiscal Recovery Funds. In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Innovative Approaches to Literacy. Questioned Costs None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed N/A Context In the samples mentioned above, In accordance with University's policy the University did not maintain the appropriate documentation for the vendors to support their assessment of whether the vendors where included on Suspension or Debarment list. In either case the vendors included in the samples were not included in the Suspension and Debarment list and the University was allowed to contract with the vendor. Cause and Effect The University did not follow its policy to ensure that the documentation verifying the vendors were not suspended or debarred. Recommendation We recommend the University reviews its procedures and controls to ensure documentation of its compliance with the requirements under uniform guidance is maintained. Views of Responsible Officials and Planned Corrective Actions A new custom validation warning will be added to the requisitions business process at the buyer approval step to require the Procurement Specialist to verify SAM.gov and attach the results as required for grant funded purchases. This custom validation will ensure that each required consideration of suspension and debarment occurs and is documented in the procurement record.

Assistance Listing, Federal Agency, and Program Name 21.027 COVID 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year SLFRP1027 Pass through Entity Michigan Strategic Fund; 20 Fathoms; Lean Rocket Lab; Talent First Inc.; Lansing Economic Area Partnership; Michigan Economic Development Corporation Finding Type Significant deficiency Repeat Finding Yes 2024 001 Criteria As outlined in 2 CFR 200.430(i), salaries and wages must be based on records that accurately reflect the work performed, including complying with established accounting policies and practices of the University. Per the University policy, effort reports are to be certified by an individual or a person with suitable means of verification (the principal investigator, department chair, or dean) of the work performed approximately 30 days after each reporting period. Condition Of the 6 employees included in the payroll expenditures sample selected for testing, the University did not complete a full, executed review of the effort certifications within the time period outlined for one employee. Questioned Costs None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed None Context In the samples mentioned above, the University completed review of the effort certification to support salaries were allowable, one of the total of 6 employees tested were not reviewed timely. Cause and Effect The University implemented a new automated process during the year to initiate the employee groups that are required to complete an effort certification; however, an employee group was excluded during the set up of the process resulting a certification that was completed outside of the University policy. Recommendation We recommend the University review employee groups maintained in the enterprise resource planning (Workday) to ensure that all employees required to perform effort certifications are included. Views of Responsible Officials and Planned Corrective Actions A new control has been added to the effort certification process that occurs prior to the distribution of effort reports for certification. The Effort Certification Administrator reconciles a compiled listing of all federal grant effort by employee name from the general ledger to ensure that an effort report is subsequently generated for each qualifying employee who worked on a federal grant during the appropriate period.

Assistance Listing, Federal Agency, and Program Name - 84.217, 84.042, 84.066, 84.047, 84.044 TRIO Cluster ("TRIO"), and 84.027 Special Education Cluster ("IDEA") Federal Award Identification Number and Year - TRIO - All Federal Award Identifications IDEA - 700005133 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2023 001 Criteria - As outlined in 2 CFR 200.430(i), salaries and wages must be based on records that accurately reflect the work performed, including complying with established accounting policies and practices of the University. Per the University policy, effort reports are to be certified by an individual or a person with suitable means of verification (the principal investigator, department chair, or dean) of the work performed approximately 30 days after each reporting period. Condition Of the 11 employees included in the hourly payroll expenditure sample selected for testing in the TRIO Cluster, the University did not complete a full, executed review of the effort certifications with the time period outlined for 1 employee. Of the 7 employees included in the hourly payroll expenditure sample selected for testing in the Special Education Cluster, the University did not complete a full, executed review of the effort certifications with the time period outlined for 5 employees. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the samples mentioned above, the University ultimately completed review of the effort certifications to support salaries and wages were allowable, however, 6 of the total 18 employees tested in these two programs were not reviewed timely. Cause and Effect - The University did not follow its policy to ensure that time and efforts were being reviewed and approved in a timely manner. Recommendation - We recommend the University maintain a procedure and control to ensure that, upon each reporting period, the University reviews and approves effort certifications as outlined in its policy. Views of Responsible Officials and Corrective Action Plan - The university implemented a new grant management software in June 2024 that provides greater functionality to complete the effort certification process within the time requirement identified in the University's Time and Effort Reporting Policy. Winter Semester 2024 was certified timely under the new system and the university considers the finding to be fully corrected. Please note that this finding occurred prior to the implementation of the new system.

Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.

Assistance Listing, Federal Agency, and Program Name - 84.027 Special Education Cluster ("IDEA") and Research and Development Cluster ("R&D") Federal Award Identification Number and Year - IDEA - 700005133 and R&D - All ALN's Pass through Entity - IDEA - N/A and R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards. (2 CFR 200.502) Condition - Out of our 40 samples tested for allowability in the Special Education Cluster, the University improperly included 2 expenditures for goods and services incurred or received in a prior year on the schedule of expenditures of federal awards (SEFA) in the current year. Out of our 40 samples tested for allowability in the Research and Development Cluster, the University improperly included 1 expenditure for goods and services incurred or received in a prior year on the schedule of expenditures of federal awards (SEFA) in the current year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - As part of the University's year end closing process, they accrue for invoices received subsequent to year end but relate to the prior fiscal year. Our sample identified two invoices that were improperly excluded from the University's analysis in the prior year and therefore were improperly included in the current year SEFA. Cause and Effect - The University did not follow its procedure to ensure all expenditures were captured in its year end analysis resulting in expenditures improperly included in the current year SEFA. Recommendation - We recommend the University review its current policy and procedures related to identifying and capturing grant expenditures in the proper period. Views of Responsible Officials and Planned Corrective Actions - The university implemented a new financial enterprise software system that allows each department within the university to improve its ability to monitor and track status of invoices as well as reduce processing time by the Accounts Payable Department to vouch approved expenditures.

CFDA Number, Federal Agency, and Program Name - 59.037, US Small Business Association, Small Business Development Center Federal Award Identification Number and Year - SBAHQ22B0059, 2023 Pass through Entity – N/A Finding Type – Significant Deficiency Repeat Finding – Yes – 2023-002 Criteria – The Federal Funding Accountability and Transparency Act as amended by section 6202 of Public Las 110-252 requires recipients of Federal awards to report data using the FFATA Subaward Reporting System (FSRS) Tool. Condition The University did not retain supporting documentation including key data elements to support timely submission of the required reports to the federal agency. Questioned Costs – None Identification of How Questioned Costs Were Computed – N/A Context – The following table summarizes the transactions examined and the non-compliance identified: See the table within the schedule of findings and questioned costs. Cause and Effect - The University did not have the proper controls in place to submit accurate data to FSRS in a timely manner. Recommendation - We recommend the University implement a procedure to determine reporting due dates and document the review of reports being submitted to FFATA timely ensuring all key data elements are included. Views of Responsible Officials and Corrective Action Plan – The Federal agency has a new reporting system for FFATA through SAM.gov that allows more accurate reporting and technical system failures. GVSU Office of Sponsored Programs will file FFATA reports within the required 30-day timeline and will share receipt of filings with GVSU finance and MI-SBDC to acknowledge timely submissions. In the event of any system failures or delays in filing, GVSU OSP will capture a screenshot of the error and work with the agency tech support team as well as notify both Finance and MI-SBDC so the agency can be informed.

Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D), Small Business Development Centers (SBDC), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Award Identification Number and Year - R&D - All ALN's SBDC - SBAHQ21B0057, SBAHQ22B0059, SBAOEDSB230049, SBAHQ20C0031 ELC - NU50CK000510 Pass through Entity - R&D - Various SBDC - None ELC - Michigan Department of Health and Human Services and Kent County Health Department Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - As outlined in 2 CFR 200.430(i), salaries and wages must be based on records that accurately reflect the work performed including complying with established accounting policies and practices of the University. Per the University's policy, effort reports are to be certified by an individual or a person with suitable means of verification (the principal investigator, department chair or Dean) of the work performed approximately 30 days after each reporting period. Condition - Of the 10 employees included within the hourly payroll expenditure sample selected for testing in the Research and Development Cluster, the University did not complete a full, executed review of the effort certifications within the time period as outlined in the policy for all 10 employees. Of the 14 employees included within the hourly payroll expenditure sample selected for testing in the Small Business Development grants, the University did not complete a full, executed review of the effort certifications within the time period as outlined in the policy for 7 employees. Of the 8 employees included within the hourly payroll expenditure sample selected for testing in the Epidemiology and Laboratory Capacity for Infectious Diseases grants, the University did not complete a full, executed review of the effort certifications within the time period as outlined in the policy for all 8 employees. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the samples mentioned above, the University ultimately completed review of the effort certifications to support salaries and wages were allowable, however, 25 of the total 32 employees tested in these three programs were not reviewed timely. Cause and Effect - The University did not follow its policy to ensure that time and efforts were being reviewed and approved in a timely manner. Recommendation - We recommend the University maintain a procedure and control in place to ensure that, upon each reporting period, the University reviews and approves effort certifications as outlined in its policy. Views of Responsible Officials and Corrective Action Plan - Management agrees. The University implemented a new grant management software that will provide greater functionality to complete the effort certification process within the time requirements as identified in the University's Time and Effort Reporting policy.

Assistance Listing, Federal Agency, and Program Name – 59.037, US Small Business Association, Small Business Development Center Federal Award Identification Number and Year – SBAHQ22B0059, 2023 Pass through Entity – N/A Finding Type – Material weakness and material non-compliance with laws and regulations Repeat Finding – No Criteria – The Federal Funding Accountability and Transparency Act (“FFATA”) as amended by section 6202 of Public Law 110-252 requires recipients of Federal awards to report data using the FFATA Subaward Reporting System (FSRS) Tool. Condition The University did not report the subaward information timely and did not report all the key data elements accurately. Questioned Costs – None Identification of How Questioned Costs Were Computed – N/A Context – The following table summarizes the transactions examined and the non-compliance identified: See the Schedule of Findings and Questioned Costs for table. Cause and Effect – The University did not have the proper controls in place to submit accurate data to FSRS in a timely manner. Recommendation – We recommend the University implement a procedure to determine reporting due dates and document the review of reports being submitted to FFATA timely ensuring all key data elements are included. Views of Responsible Officials and Corrective Action Plan - Management agrees. When the University is unable to access the FFATA system, University staff will capture a screen snip of the error message and save it to the secure shared drive and follow-up with an email to the system’s help desk prior to the 30-day reporting requirement.

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