EIN: 381880022
UEI: LMJAVFPBYQ74
Audited by: Rehmann Robson LLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 17, 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 17, 2026 (18 days from today).
What is a management decision? →Noncompliance with 10-Day Rule (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University may not disburse funds to a student more than 10 days before the start of a semester. Condition. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. Cause. The University lacks a review process to ensure the timing of funds distributed to students is in accordance with federal guidelines. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Noncompliance with 10-Day Rule (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University may not disburse funds to a student more than 10 days before the start of a semester. Condition. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. Cause. The University lacks a review process to ensure the timing of funds distributed to students is in accordance with federal guidelines. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. As a result of this condition, the University is not in compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
2024-003
Miscalculation of Student Cost of Attendance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University must accurately estimate the cost to attend the university for the fiscal year. Condition. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. Cause. The University lacks a review process to ensure student budgets are locked upon initial packaging and cannot be modified without appropriate review and approval. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked after initial packaging and no changes made without proper review and approval. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Miscalculation of Student Cost of Attendance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. The University must accurately estimate the cost to attend the university for the fiscal year. Condition. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. Cause. The University lacks a review process to ensure student budgets are locked upon initial packaging and cannot be modified without appropriate review and approval. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked after initial packaging and no changes made without proper review and approval. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the University is out of compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked and no changes made without proper review and approval. Corrective Action. The University will implement a review process to ensure that all student budgets are reviewed and locked. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Lack of Review over Financial Status Reports Finding Type. Significant Deficiency in Internal Control over Compliance (Cash Management and Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Per 2 CFR §200.305(b), non-federal entities must minimize the time elapsing between the transfer of funds and disbursement, and also must maintain accurate financial records and submit required Federal Financial Status Reports ("FSR"). Entities must also ensure that drawdowns and FSRs are complete, based on actual, allowable expenditures, supported by underlying accounting records, and prepared in accordance with Federal requirements. Condition. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. Cause. The University lacked formal internal controls and oversight mechanisms to ensure drawdowns and FSRs were reviewed prior to submission. The process relied on informal practices without documented policies or designated reviewers. Effect. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. The University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Lack of Review over Financial Status Reports Finding Type. Significant Deficiency in Internal Control over Compliance (Cash Management and Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Per 2 CFR §200.305(b), non-federal entities must minimize the time elapsing between the transfer of funds and disbursement, and also must maintain accurate financial records and submit required Federal Financial Status Reports ("FSR"). Entities must also ensure that drawdowns and FSRs are complete, based on actual, allowable expenditures, supported by underlying accounting records, and prepared in accordance with Federal requirements. Condition. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. Cause. The University lacked formal internal controls and oversight mechanisms to ensure drawdowns and FSRs were reviewed prior to submission. The process relied on informal practices without documented policies or designated reviewers. Effect. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. The University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Lack of Review over Financial Status Reports Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Auditor Recommendation. We recommend that the University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. Corrective Action. The University will implement a review process to ensure that all drawdowns are reviewed by a second individual prior to submission. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Untimely Submission of Financial Status Reports (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Financial Status Reports must be submitted to the Department's EGrAMS website on a monthly basis, no later than 30 days after the close of each calendar month. Condition. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. Cause. The University lacks a review process to ensure the Financial Status Reports are submitted within the submission period. Effect. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Untimely Submission of Financial Status Reports (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Financial Status Reports must be submitted to the Department's EGrAMS website on a monthly basis, no later than 30 days after the close of each calendar month. Condition. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. Cause. The University lacks a review process to ensure the Financial Status Reports are submitted within the submission period. Effect. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Lack of Review and Timely Filing of Financial Status Reports (Repeat finding) Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Auditor Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. Corrective Action. The University will establish and follow an internal controls policy that requires review and approval prior to submitting financial status report timely. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
2024-007
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Auditor Description of Condition and Effect. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Auditor Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. Corrective Action. The University will maintain documentation for sole-source arrangements and approval of supporting documents to remain in compliance with bid policy and federal guidelines. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
2024-008
Non-Compliance with Servicer to Deliver Title IV Credit Balances Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.164(e), institutions that enter into Tier Two Arrangements must maintain a written agreement with the financial institution, disclose the agreement publicly on the institution's website, conduct and document a free biennial review, report the arrangement to Federal Student Aid, and implement internal controls to ensure compliance. Condition. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Cause. The University has not developed or implemented formal compliance procedures for Tier Two Arrangement requirements. Effect. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Non-Compliance with Servicer to Deliver Title IV Credit Balances Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.164(e), institutions that enter into Tier Two Arrangements must maintain a written agreement with the financial institution, disclose the agreement publicly on the institution's website, conduct and document a free biennial review, report the arrangement to Federal Student Aid, and implement internal controls to ensure compliance. Condition. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Cause. The University has not developed or implemented formal compliance procedures for Tier Two Arrangement requirements. Effect. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Auditor Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. Corrective Action. The University will create a formal Banking Services Agreement with the Financial Institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
2025-009 – Insufficient Supporting Documentation of Disbursements Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.403(g) and 2 CFR 200.334, federal award expenses must be adequately documented, and records must be retained and available for review for the required retention period. Condition. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. Cause. The lack of required supporting documentation resulted from employee turnover within the grant and accounts payable functions, which led to gaps in knowledge transfer and inconsistent adherence to established documentation procedures. Effect. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. There were questioned costs of $135. Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2025-009 – Insufficient Supporting Documentation of Disbursements Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.403(g) and 2 CFR 200.334, federal award expenses must be adequately documented, and records must be retained and available for review for the required retention period. Condition. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. Cause. The lack of required supporting documentation resulted from employee turnover within the grant and accounts payable functions, which led to gaps in knowledge transfer and inconsistent adherence to established documentation procedures. Effect. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. There were questioned costs of $135. Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Insufficient Supporting Documentation of Disbursements Auditor Description of Condition and Effect. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Corrective Action. The University will establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
2025-010 – Indirect Cost Rate Review Finding Type. Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.400(e), when reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, the cognizant agency for indirect costs should ensure that the recipient consistently applies these cost principles. Condition. The University does not have a formal review process related to indirect cost rate automated entries. Cause. The University has not developed or implemented formal review procedures related to indirect costs. Effect. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2025-010 – Indirect Cost Rate Review Finding Type. Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. Under 2 CFR §200.400(e), when reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, the cognizant agency for indirect costs should ensure that the recipient consistently applies these cost principles. Condition. The University does not have a formal review process related to indirect cost rate automated entries. Cause. The University has not developed or implemented formal review procedures related to indirect costs. Effect. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Indirect Cost Rate Review Auditor Description of Condition and Effect. The University does not have a formal review process related to indirect cost rate automated entries. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. Corrective Action. The University will establish formal procedures to review the indirect cost rate input and automated entries by additional individual on a monthly or quarterly basis. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Incorrect Term Dates Used in R2T4 Calculations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.22, institutions are required to calculate the percentage of Title IV aid earned based on the number of calendar days completed in the payment period or period of enrollment, beginning with the actual first day of the term as defined by the institution’s academic calendar. Condition. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. Cause. Controls were not in place to ensure the term start date used in R2T4 calculations was verified against the academic calendar prior to processing. Effect. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Questioned Costs. There were questioned costs of $96. Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Incorrect Term Dates Used in R2T4 Calculations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.22, institutions are required to calculate the percentage of Title IV aid earned based on the number of calendar days completed in the payment period or period of enrollment, beginning with the actual first day of the term as defined by the institution’s academic calendar. Condition. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. Cause. Controls were not in place to ensure the term start date used in R2T4 calculations was verified against the academic calendar prior to processing. Effect. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Questioned Costs. There were questioned costs of $96. Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
FAC accepted this audit on March 25, 2025 — management decision was due September 25, 2025.
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles; Period of Performance). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Criteria. The University must pay employees in accordance with the pay authorizations timing issued by the University and approved by grant personnel. Condition. The authorized payment period for the grant was from October 1, 2023, to July 30, 2024, covering a total of 22 weeks. However, payroll distributions were made over a span of 26 weeks, thereby exceeding the authorized period by 4 weeks. Cause. The University does not have a review process in place for ensuring that grant payments are paid in the correct pay period. Effect. As a result of this condition, the University was out of compliance with the terms and conditions of the grant agreement. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that the terms and conditions of each grant are understood and carried out according to the agreement. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles; Period of Performance). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Criteria. The University must pay employees in accordance with the pay authorizations timing issued by the University and approved by grant personnel. Condition. The authorized payment period for the grant was from October 1, 2023, to July 30, 2024, covering a total of 22 weeks. However, payroll distributions were made over a span of 26 weeks, thereby exceeding the authorized period by 4 weeks. Cause. The University does not have a review process in place for ensuring that grant payments are paid in the correct pay period. Effect. As a result of this condition, the University was out of compliance with the terms and conditions of the grant agreement. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that the terms and conditions of each grant are understood and carried out according to the agreement. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. The authorized payment period for the grant was from October 1, 2023, to July 30, 2024, covering a total of 22 weeks. However, payroll distributions were made over a span of 26 weeks, thereby exceeding the authorized period by 4 weeks. As a result of this condition, the University was out of compliance with the terms and conditions of the grant agreement. Auditor Recommendation. We recommend that the University implement a review process to ensure that the terms and conditions of each grant are understood and carried out according to the agreement. Corrective Action. The University will amend its policies and procedures to have a second reviewer access each grant to ensure the terms and conditions are understood and being followed. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Programs. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Research and Development Cluster; U.S. Department of the Interior and U.S. Environmental Protection Agency; Assistance Listing Numbers 15.662 and 66.469; Award Numbers F22AP02820-00, GL-00E02930/FISH2 2021-11, and F64661. Criteria. When pay rates are approved and authorized by the University, the University must adhere to and pay the rate prescribed. Condition. The payment rates authorized for employees working under the grants were not correctly and uniformly applied and four employees were paid at unauthorized rates. Cause. The University does not have a review process in place to ensure all authorized payment amounts agree with the amounts actually paid. Effect. As a result of this condition, the University is at a greater risk of charging unauthorized amounts to the grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that payment rate amounts reflect the amounts authorized for payment and that the payment rates are being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Programs. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Research and Development Cluster; U.S. Department of the Interior and U.S. Environmental Protection Agency; Assistance Listing Numbers 15.662 and 66.469; Award Numbers F22AP02820-00, GL-00E02930/FISH2 2021-11, and F64661. Criteria. When pay rates are approved and authorized by the University, the University must adhere to and pay the rate prescribed. Condition. The payment rates authorized for employees working under the grants were not correctly and uniformly applied and four employees were paid at unauthorized rates. Cause. The University does not have a review process in place to ensure all authorized payment amounts agree with the amounts actually paid. Effect. As a result of this condition, the University is at a greater risk of charging unauthorized amounts to the grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that payment rate amounts reflect the amounts authorized for payment and that the payment rates are being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. The payment rates authorized for employees working under the grants were not correctly and uniformly applied and four employees were paid at unauthorized rates. As a result of this condition, the University is at a greater risk of charging unauthorized amounts to the grant. Auditor Recommendation. We recommend that the University implement a review process to ensure that payment rate amounts reflect the amounts authorized for payment and that the payment rates are being reviewed by a second individual. Corrective Action. The University will implement a review process to ensure that the payment rate amounts reflect the amounts authorized for payment and that the payments are being reviewed by a second individual. Responsible Person. Kim Swailes, Assistant Director of Human Resources & Payroll Administrator Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The University may not disburse funds to a student more than 10 days before the start of a semester. Condition. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. Cause. The University lacks a review process to ensure the timing of funds distributed to students is in accordance with federal guidelines. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The University may not disburse funds to a student more than 10 days before the start of a semester. Condition. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. Cause. The University lacks a review process to ensure the timing of funds distributed to students is in accordance with federal guidelines. Effect. As a result of this condition, the University is not in compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. As a result of this condition, the University is not in compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. When the disbursement of aid creates a credit balance, the University must pay the credit balance to the student or parent borrower within 14 days. Condition. Of the 40 students tested, we noted 7 students that had their credit balances paid to them outside of the 14-day period. Cause. The University does not have a review process in place to ensure all payments to students are made timely and within prescribed federal guidelines. Effect. As a result of this condition, the University is out of compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all payments to students are made timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. When the disbursement of aid creates a credit balance, the University must pay the credit balance to the student or parent borrower within 14 days. Condition. Of the 40 students tested, we noted 7 students that had their credit balances paid to them outside of the 14-day period. Cause. The University does not have a review process in place to ensure all payments to students are made timely and within prescribed federal guidelines. Effect. As a result of this condition, the University is out of compliance with federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure that all payments to students are made timely and within prescribed federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. Of the 40 students tested, we noted 7 students that had their credit balances paid to them outside of the 14-day period. As a result of this condition, the University is out of compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all payments to students are made timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The Federal Trade Commission ("FTC") states that the Gramm Leach Bliley Act "requires financial institutions to explain their information-sharing practices to their customers and safeguard sensitive data." This act states that institutions must clearly document the design and implementation of safeguards to control the risks identifed through the institution's risk assessment. Condition. The most recent Gramm Leach Bliley policy fails to properly describe the design and implementation of safeguard controls as required by the Gramm Leach Bliley Act. The University's Gramm Leach Bliley policy does not provide in-depth explanations as to the steps the University takes to comply with the Gramm Leach Bliley Act. Cause. The University does not have a review process in place to ensure all safeguard policies set forth in the Gramm Leach Bliley Act are adequately met in its Gramm Leach Bliley policy. Effect. As a result of this condition, the University isn't meeting the safeguard requirements necessary to comply with the FTC. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University revise its Gramm Leach Bliley policy to expand upon how it ensures that all Gramm Leach Bliley safeguards in the Gramm Leach Bliley Act are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The Federal Trade Commission ("FTC") states that the Gramm Leach Bliley Act "requires financial institutions to explain their information-sharing practices to their customers and safeguard sensitive data." This act states that institutions must clearly document the design and implementation of safeguards to control the risks identifed through the institution's risk assessment. Condition. The most recent Gramm Leach Bliley policy fails to properly describe the design and implementation of safeguard controls as required by the Gramm Leach Bliley Act. The University's Gramm Leach Bliley policy does not provide in-depth explanations as to the steps the University takes to comply with the Gramm Leach Bliley Act. Cause. The University does not have a review process in place to ensure all safeguard policies set forth in the Gramm Leach Bliley Act are adequately met in its Gramm Leach Bliley policy. Effect. As a result of this condition, the University isn't meeting the safeguard requirements necessary to comply with the FTC. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University revise its Gramm Leach Bliley policy to expand upon how it ensures that all Gramm Leach Bliley safeguards in the Gramm Leach Bliley Act are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley policy fails to properly describe the design and implementation of safeguard controls as required by the Gramm Leach Bliley Act. The University's Gramm Leach Bliley policy does not provide in-depth explanations as to the steps the University takes to comply with the Gramm Leach Bliley Act. As a result of this condition, the University isn't meeting the safeguard requirements necessary to comply with the FTC. Auditor Recommendation. We recommend that the University revise its Gramm Leach Bliley policy to expand upon how it ensures that all Gramm Leach Bliley safeguards in the Gramm Leach Bliley Act are met and verified by a second individual. Corrective Action. The University will revise its Gramm Leach Bliley policy to expand upon how it ensures that all Gramm Leach Bliley Policies in the Gramm Leach Bliley Act are met and verified by a second individual. Responsible Person. Julie Hober, Director of IT Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by 34 CFR 668.22(f) of the OMB Compliance Supplement. Condition. The University did not include weekend days when calculating breaks in the University's calculation of term days in Return to Title IV calculations. This omission led to incorrect calculations for all students who had returns during the Fall 2023 and Spring 2024 semesters. Cause. The University does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return to Title IV calculations were incorrect for 3 students for the Fall 2023 semester and 3 students for the Spring 2024 semester, resulting in a net of $1,722 in excess funds returned to the U.S. Department of Education. It is our understanding that the University is in the process of correcting student accounts as a result of this finding with expected completion prior to the end of fiscal year 2025. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure the number of enrollment days used in the Return to Title IV calculations is accurate and that the Return to Title IV calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 93.364; Award Numbers P007A222029, P007A232029, P033A232029, P038A172029, P063P220235, P063P230235, P268K230235 and P268K240235. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by 34 CFR 668.22(f) of the OMB Compliance Supplement. Condition. The University did not include weekend days when calculating breaks in the University's calculation of term days in Return to Title IV calculations. This omission led to incorrect calculations for all students who had returns during the Fall 2023 and Spring 2024 semesters. Cause. The University does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return to Title IV calculations were incorrect for 3 students for the Fall 2023 semester and 3 students for the Spring 2024 semester, resulting in a net of $1,722 in excess funds returned to the U.S. Department of Education. It is our understanding that the University is in the process of correcting student accounts as a result of this finding with expected completion prior to the end of fiscal year 2025. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a review process to ensure the number of enrollment days used in the Return to Title IV calculations is accurate and that the Return to Title IV calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. The University did not include weekend days when calculating breaks in the University's calculation of term days in Return to Title IV calculations. This omission led to incorrect calculations for all students who had returns during the Fall 2023 and Spring 2024 semesters. As a result of this condition, Return to Title IV calculations were incorrect for 9 students for the Fall 2023 semester and 13 students for the Spring 2024 semester, resulting in a net of $1,722 in excess funds returned to the U.S. Department of Education. It is our understanding that the University is in the process of correcting student accounts as a result of this finding with expected completion prior to the end of fiscal year 2025. Auditor Recommendation. We recommend that the University implement a review process to ensure the number of enrollment days used in the Return to Title IV calculations is accurate and that the Return to Title IV calculation is being reviewed by a second individual. Corrective Action. To prevent a similar problem arising in the future, the University has developed a review process that will require an additional sign-off for the total days to be used in the calculation. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Criteria. Financial Status Reports must be submitted to the Department's EGrAMS website on a monthly basis, no later than 30 days after the close of each calendar month. Condition. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. Cause. The University lacks a review process to ensure the Financial Status Reports are submitted within the submission period. Effect. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Criteria. Financial Status Reports must be submitted to the Department's EGrAMS website on a monthly basis, no later than 30 days after the close of each calendar month. Condition. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. Cause. The University lacks a review process to ensure the Financial Status Reports are submitted within the submission period. Effect. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Auditor Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. Corrective Action. The University will implement a process to ensure that all Financial Status Reports are submitted within the submission period required by the grant. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2025
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Programs. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Research and Development Cluster; National Science Foundation; Assistance Listing Number 47.083; Award Number 2320397. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Programs. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award numbers E20232322-00 and E20242798-00. Research and Development Cluster; National Science Foundation; Assistance Listing Number 47.083; Award Number 2320397. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Auditor Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. Corrective Action. The University will implement a process to ensure that documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines is maintained. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2025
FAC accepted this audit on April 10, 2024 — management decision was due October 10, 2024.
As of June 30, 2023, the University had only completed bank reconciliations through October 2022. Questioned Costs: None. Effect: Delayed reconciliations and lack of independent approval can increase the risk that potential accounting errors, should they occur, might not be detected and corrected on a timely basis. Cause: Changes in the assignment of accounting functions and staffing realignments, partially due to staff turnover and increased workloads, created a condition where certain accounting functions were not performed timely. Recommendation: The University should continue to monitor the progress of the reconciliations process to ensure all cash and investment accounts are reconciled and independently approved in a timely manner each month. Management’s Response: The University has corrected this condition with the outcome that bank and investment reconciliation as of June 30, 2023, are now current, and has implemented procedures to ensure timeliness in fiscal year 2024. Section III – Federal Award Findings and Questioned Costs No matters were reported.
Show full finding ▾Hide full finding ▴2023-1 - Timely Bank Reconciliations Criteria: Best practices under a system of internal control require timely bank and investment account reconciliations and independent approval. Condition: As of June 30, 2023, the University had only completed bank reconciliations through October 2022. Questioned Costs: None. Effect: Delayed reconciliations and lack of independent approval can increase the risk that potential accounting errors, should they occur, might not be detected and corrected on a timely basis. Cause: Changes in the assignment of accounting functions and staffing realignments, partially due to staff turnover and increased workloads, created a condition where certain accounting functions were not performed timely. Recommendation: The University should continue to monitor the progress of the reconciliations process to ensure all cash and investment accounts are reconciled and independently approved in a timely manner each month. Management’s Response: The University has corrected this condition with the outcome that bank and investment reconciliation as of June 30, 2023, are now current, and has implemented procedures to ensure timeliness in fiscal year 2024. Section III – Federal Award Findings and Questioned Costs No matters were reported.
Finding Number: 2023-01 Bank Reconciliations Condition: As of June 30, 2023, the University had only completed bank reconciliations and approvals through October 2022. Planned Corrective Action: The University concurs with the finding and has already remedied the condition and bank reconciliations are now current and being completed and reviewed on a monthly basis. Contact person responsible for corrective action: Crystal Wilcox, Director of Finance Completion Date: October 10, 2023
2022-001
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
FAC accepted this audit on September 20, 2022 — management decision was due March 20, 2023.
FAC accepted this audit on June 28, 2021 — management decision was due December 28, 2021.
The University has not completed a risk assessment that addresses those areas noted in 16 CFR 314.4(b). This was due to conditions and shifting priorities caused by the COVID-19 Pandemic. Cause: The University is still in the process of formalizing the risk assessment. Effect: Because of the failure to formalize a documented risk assessment, the University may not be aware of risks to student information and therefore may not have implemented proper information security controls. Recommendation: We recommend that the University formalize a risk assessment, which at minimum addresses the required areas. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the above finding. The University has a plan in place to develop an IT Security Audit team to address the above concerns related to risk assessment. The plan will occur during the 2020-2021 fiscal year.
Show full finding ▾Hide full finding ▴2020-001 Information Security Program and Risk Assessment ? Repeat Finding Criteria: The University is required to designate an individual to coordinate the information security program and perform a risk assessment that addresses those areas noted in 16 CFR 314.4(b) and document safeguards for identified risks. Condition: The University has not completed a risk assessment that addresses those areas noted in 16 CFR 314.4(b). This was due to conditions and shifting priorities caused by the COVID-19 Pandemic. Cause: The University is still in the process of formalizing the risk assessment. Effect: Because of the failure to formalize a documented risk assessment, the University may not be aware of risks to student information and therefore may not have implemented proper information security controls. Recommendation: We recommend that the University formalize a risk assessment, which at minimum addresses the required areas. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the above finding. The University has a plan in place to develop an IT Security Audit team to address the above concerns related to risk assessment. The plan will occur during the 2020-2021 fiscal year.
As of January 7, 2021, Morrie Walworth, Vice President for Finance and Operations, has designated an employee to become an IT Security Auditor. Weekly meetings have began with the IT Security Committee as well. The committee includes functional representation of network, server and desktop administration. These meetings range from 1 hour to all day working sessions depending on need. This committee performs an annual review of data inventory, risk and controls. This includes evaluations of network access, data storage, software design, data transmission and disposal culminating in a risk assessment. When not actively performing the security audit the committee seeks to implement recommendations collaboratively, identify trends, and address emerging threats.
2019-001
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
The University has not completed a risk assessment that addresses those areas noted in 16 CFR 314.4(b). Cause: The University is still in the process of formalizing the risk assessment. Effect: Because of the failure to formalize a documented risk assessment, the University may not be aware of risks to student information and therefore may not have implemented proper information security controls. Recommendation: We recommend that the University formalize a risk assessment, which at minimum addresses the required areas. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the above finding. The University has a plan in place to develop an IT Security Audit team to address the above concerns related to risk assessment. The plan will occur during the 2019-2020 fiscal year.
Show full finding ▾Hide full finding ▴2019-001 Information Security Program and Risk Assessment Criteria: The University is required to designate an individual to coordinate the information security program and perform a risk assessment that addresses those areas noted in 16 CFR 314.4(b) and document safeguards for identified risks. Condition: The University has not completed a risk assessment that addresses those areas noted in 16 CFR 314.4(b). Cause: The University is still in the process of formalizing the risk assessment. Effect: Because of the failure to formalize a documented risk assessment, the University may not be aware of risks to student information and therefore may not have implemented proper information security controls. Recommendation: We recommend that the University formalize a risk assessment, which at minimum addresses the required areas. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the above finding. The University has a plan in place to develop an IT Security Audit team to address the above concerns related to risk assessment. The plan will occur during the 2019-2020 fiscal year.
Morrie Walworth, Vice President for Finance and Operations, has a plan in place to develop an IT Security Audit team to address the above concerns related to risk assessment. The plan will be put in place by June 30, 2020.
FAC accepted this audit on February 10, 2019 — management decision was due August 10, 2019.
FAC accepted this audit on January 10, 2018 — management decision was due July 10, 2018.
FAC accepted this audit on December 29, 2016 — management decision was due June 29, 2017.
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