EIN: 430654872
UEI: JNBLLTBTLLD8
Audited by: KPMG
Cognizant agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (28 days from today).
What is a management decision? →Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: • One student who graduated in May 2025 was reported as withdrawn (W) instead of graduated (G). Upon further review, we noted the University had submitted a revision of this student’s W status after completing the evaluation of the student’s academic record to confer their degree; however, the change was rejected by NSLDS. The student was identified on a graduate error report provided by the National Student Clearinghouse (the University’s service organization) which included 171 graduated students with record errors that need to be resolved. Because the University submits all graduated students to NSLDS, the majority of the errors on this report (132) relate to individuals who did not receive Title IV awards during 2024-2025. Given the majority of the errors on the report were expected given the University’s process and the remaining population of errors was small, the University’s internal controls were not designed at a level of precision to ensure the resolution of the remaining 39 errors related to Title IV recipients were consistently documented or processed in a timely manner. We noted the University’s controls were not operating effectively to ensure all enrollment changes identified within the graduate error reports were timely and accurately resolved at a level of precision to report any necessary corrections to the NSLDS within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by not timely resolving graduate errors identified by NSC and updating all systems after resolving NSC error reports. Personnel constraints led to these reports not being timely resolved. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was reported in prior year as 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: After review of the “Cause” articulated in the finding document Saint Louis University’s (SLU) Office of the University Registrar (OUR) has determined that this “Cause” needs further context on the cause of errors. As addressed below, it is accurate that the OUR failed to, in a timely manner, (a) resolve some errors identified by NSC and (b) update all systems after error resolution; and it is accurate that staffing concerns, including staff reductions in the OUR in recent years, contributed substantively to this failure. NSC’s records and processes errantly define some data as erroneous. For example: When SLU submits a degree file to the NSC, the NSC transfers the degree records to the NSC “Degree Verify” system, checks for duplicates, etc. The NSC then uses that data to update previously submitted enrollment files and assigns, when applicable, the “Graduated” status to students SLU included in degree file. NSC, not SLU, is unable to update the “Graduated” status to some records. Reasons for this include, but are not limited to the following: • The student’s last enrollment was not in the term in which the degree was awarded The student has multiple degree and/or curriculum records in SLU’s systems and NSC has issues reconciling the multiple degrees in their system. The student is still actively enrolled in another degree program at SLU. Accordingly, to be clear, OUR accurately reports graduation data to the NSC where, due to limitations of NSC’s own processes, cannot accurately process. This results in errors that SLU is then obligated to correct (although the errors are not, technically, SLU’s errors). While OUR recognize that, in an audit, such errors will present as “SLU errors,” OUR think it is important that everyone understand the true nature of these errors. Regardless of whether a student record error was either (a) made by SLU itself or (b) ”created” by the NSC due to its own limitations as described above, those errors need to be corrected. When, for whatever reason, the NSC identifies SLU graduation data as erroneous, OUR can identify such student records via an error reporting process provided by the NSC. The NSC requires SLU (and all institutions) to correct any such erroneous records within 30 days. There are three issues to address as OUR evaluates why SLU has failed to always rectify errors within that 30-day window. First, that 30-day window is not, in fact, always a 30-day window. Some student records, at some point during the 30-day window, are locked by the NSC when the NSC receives enrollment data updates about those students; the NSC’s system cannot both (a) process new enrollment records for a student while (b) SLU also attempts to correct errors related to graduation status. So, for students whose enrollment records change during that 30-day period, SLU is locked out of the NSC’s system to correct graduation status errors. If, therefore, for example, a student’s erroneous graduation records have been “open” for SLU remediation for 10 days but then the NSC locks the records because that student also has updated enrollment records in process, SLU’s window for correcting the erroneous graduation records has been limited to just 10 days. If the NSC re-opens that record before the full 30-day window has expired, NSC will re-open the graduation record for SLU to re-attempt correction. However, that again requires regular SLU monitoring of the changing file statuses and a window for correction less than the prescribed 30 days. The amount of manual monitoring of this system for record compliance and remediation is extensive, and particularly problematic given the staffing limitations of the OUR. The second issue impacting SLU’s ability to remedy erroneous responses within the 30-day window is that the NSC’s systems cannot “handle” multiple graduation-related changes when students are/have been enrolled in more than one SLU program at a time. In other words: SLU sometimes cannot – due to NSC data system limitations – make the necessary corrections to graduation data for a student’s first program (“Program A”) when the student is also still enrolled in a second program (“Program B”). In fact, if SLU changed graduation data for Program A, it would result in new errors related to the student’s accurate, continuous enrollment (pre-graduation) in Program B. SLU cannot “win” either way in this predicament; one way or another, SLU’s records in the NSC will be “wrong” (depending on your vantage point). One remedy to this situation is for the OUR to regularly inform the Office of Student Financial Services (SFS) of the situation and request SFS manually update the records directly in the NSLDS system (to which the OUR does not have access). The OUR will implement this change to controls going forward, knowing that this represents additional manual monitoring and action. The third issue to address is similar. Due to flaws in the NSLDS’ own systems, the NSLDS does not record the accurate graduation dates for a select set of students (those whose graduation dates are different from their last dates of enrollment at SLU). In these cases (as in the situation above), the OUR cannot remediate this via its access to the NSC; the problem must be resolved in the NSLDS system, to which the OUR Registrar does not have access. Accordingly, the remedy to this situation is for the OUR to regularly inform the (SFS) of the situation and request SFS manually update the records directly in the NSLDS. The OUR will implement this change to internal controls going forward, knowing that this represents additional manual monitoring and action. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: • One student who graduated in May 2025 was reported as withdrawn (W) instead of graduated (G). Upon further review, we noted the University had submitted a revision of this student’s W status after completing the evaluation of the student’s academic record to confer their degree; however, the change was rejected by NSLDS. The student was identified on a graduate error report provided by the National Student Clearinghouse (the University’s service organization) which included 171 graduated students with record errors that need to be resolved. Because the University submits all graduated students to NSLDS, the majority of the errors on this report (132) relate to individuals who did not receive Title IV awards during 2024-2025. Given the majority of the errors on the report were expected given the University’s process and the remaining population of errors was small, the University’s internal controls were not designed at a level of precision to ensure the resolution of the remaining 39 errors related to Title IV recipients were consistently documented or processed in a timely manner. We noted the University’s controls were not operating effectively to ensure all enrollment changes identified within the graduate error reports were timely and accurately resolved at a level of precision to report any necessary corrections to the NSLDS within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by not timely resolving graduate errors identified by NSC and updating all systems after resolving NSC error reports. Personnel constraints led to these reports not being timely resolved. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was reported in prior year as 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: After review of the “Cause” articulated in the finding document Saint Louis University’s (SLU) Office of the University Registrar (OUR) has determined that this “Cause” needs further context on the cause of errors. As addressed below, it is accurate that the OUR failed to, in a timely manner, (a) resolve some errors identified by NSC and (b) update all systems after error resolution; and it is accurate that staffing concerns, including staff reductions in the OUR in recent years, contributed substantively to this failure. NSC’s records and processes errantly define some data as erroneous. For example: When SLU submits a degree file to the NSC, the NSC transfers the degree records to the NSC “Degree Verify” system, checks for duplicates, etc. The NSC then uses that data to update previously submitted enrollment files and assigns, when applicable, the “Graduated” status to students SLU included in degree file. NSC, not SLU, is unable to update the “Graduated” status to some records. Reasons for this include, but are not limited to the following: • The student’s last enrollment was not in the term in which the degree was awarded The student has multiple degree and/or curriculum records in SLU’s systems and NSC has issues reconciling the multiple degrees in their system. The student is still actively enrolled in another degree program at SLU. Accordingly, to be clear, OUR accurately reports graduation data to the NSC where, due to limitations of NSC’s own processes, cannot accurately process. This results in errors that SLU is then obligated to correct (although the errors are not, technically, SLU’s errors). While OUR recognize that, in an audit, such errors will present as “SLU errors,” OUR think it is important that everyone understand the true nature of these errors. Regardless of whether a student record error was either (a) made by SLU itself or (b) ”created” by the NSC due to its own limitations as described above, those errors need to be corrected. When, for whatever reason, the NSC identifies SLU graduation data as erroneous, OUR can identify such student records via an error reporting process provided by the NSC. The NSC requires SLU (and all institutions) to correct any such erroneous records within 30 days. There are three issues to address as OUR evaluates why SLU has failed to always rectify errors within that 30-day window. First, that 30-day window is not, in fact, always a 30-day window. Some student records, at some point during the 30-day window, are locked by the NSC when the NSC receives enrollment data updates about those students; the NSC’s system cannot both (a) process new enrollment records for a student while (b) SLU also attempts to correct errors related to graduation status. So, for students whose enrollment records change during that 30-day period, SLU is locked out of the NSC’s system to correct graduation status errors. If, therefore, for example, a student’s erroneous graduation records have been “open” for SLU remediation for 10 days but then the NSC locks the records because that student also has updated enrollment records in process, SLU’s window for correcting the erroneous graduation records has been limited to just 10 days. If the NSC re-opens that record before the full 30-day window has expired, NSC will re-open the graduation record for SLU to re-attempt correction. However, that again requires regular SLU monitoring of the changing file statuses and a window for correction less than the prescribed 30 days. The amount of manual monitoring of this system for record compliance and remediation is extensive, and particularly problematic given the staffing limitations of the OUR. The second issue impacting SLU’s ability to remedy erroneous responses within the 30-day window is that the NSC’s systems cannot “handle” multiple graduation-related changes when students are/have been enrolled in more than one SLU program at a time. In other words: SLU sometimes cannot – due to NSC data system limitations – make the necessary corrections to graduation data for a student’s first program (“Program A”) when the student is also still enrolled in a second program (“Program B”). In fact, if SLU changed graduation data for Program A, it would result in new errors related to the student’s accurate, continuous enrollment (pre-graduation) in Program B. SLU cannot “win” either way in this predicament; one way or another, SLU’s records in the NSC will be “wrong” (depending on your vantage point). One remedy to this situation is for the OUR to regularly inform the Office of Student Financial Services (SFS) of the situation and request SFS manually update the records directly in the NSLDS system (to which the OUR does not have access). The OUR will implement this change to controls going forward, knowing that this represents additional manual monitoring and action. The third issue to address is similar. Due to flaws in the NSLDS’ own systems, the NSLDS does not record the accurate graduation dates for a select set of students (those whose graduation dates are different from their last dates of enrollment at SLU). In these cases (as in the situation above), the OUR cannot remediate this via its access to the NSC; the problem must be resolved in the NSLDS system, to which the OUR Registrar does not have access. Accordingly, the remedy to this situation is for the OUR to regularly inform the (SFS) of the situation and request SFS manually update the records directly in the NSLDS. The OUR will implement this change to internal controls going forward, knowing that this represents additional manual monitoring and action. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
The below includes the recommendation and our corrective action plans for the 2025 Audit Findings. Finding 2024-003 and 2025-001 - Reporting We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within the required timeframes. Regardless of whether a student record error was either (a) made by Saint Louis University (SLU) itself or (b) “created” by the NSC due to its own limitations as described in Response #1 above, those errors need to be corrected. When, for whatever reason, the NSC identifies SLU graduation data as erroneous, Office of the University Registrar (OUR) can identify such student records via an error reporting process provided by the NSC. The NSC requires SLU (and all institutions) to correct any such erroneous records within 30 days. There are three issues to address as OUR evaluates why SLU has failed to always rectify errors within that 30-day window. First, that 30-day window is not, in fact, always a 30-day window. Some student records, at some point during the 30-day window, are locked by the NSC when the NSC receives enrollment data updates about those students; the NSC’s system cannot both (a) process new enrollment records for a student while (b) SLU also attempts to correct errors related to graduation status. So, for students whose enrollment records change during that 30-day period, SLU is locked out of the NSC’s system to correct graduation status errors. If, therefore, for example, a student’s erroneous graduation records have been “open” for SLU remediation for 10 days but then the NSC locks the records because that student also has updated enrollment records in process, SLU’s window for correcting the erroneous graduation records has been limited to just 10 days. If the NSC re-opens that record before the full 30-day window has expired, NSC will re-open the graduation record for SLU to re-attempt correction. However, that again requires regular SLU monitoring of the changing file statuses and a window for correction less than the prescribed 30 days. The amount of manual monitoring of this system for record compliance and remediation is extensive, and particularly problematic given the staffing limitations of the OUR. The second issue impacting SLU’s ability to remedy erroneous responses within the 30-day window is that the NSC’s systems cannot “handle” multiple graduation-related changes when students are/have been enrolled in more than one SLU program at a time. In other words: SLU sometimes cannot – due to NSC data system limitations – make the necessary corrections to graduation data for a student’s first program (“Program A”) when the student is also still enrolled in a second program (“Program B”). In fact, if SLU changed graduation data for Program A, it would result in new errors related to the student’s accurate, continuous enrollment (pre-graduation) in Program B. SLU cannot “win” either way in this predicament; one way or another, SLU’s records in the NSC will be “wrong” (depending on your vantage point). One remedy to this situation is for the OUR to regularly inform the Office of Student Financial Services (SFS) of the situation and request SFS manually update the records directly in the NSLDS system (to which the OUR does not have access). The OUR will implement this change to controls going forward, knowing that this represents additional manual monitoring and action. The third issue to address is similar. Due to flaws in the NSLDS’ own systems, the NSLDS does not record the accurate graduation dates for a select set of students (those whose graduation dates are different from their last dates of enrollment at SLU). In these cases (as in the situation above), the OUR cannot remediate this via its access to the NSC; the problem must be resolved in the NSLDS system, to which the OUR Registrar does not have access. Accordingly, the remedy to this situation is for the OUR to regularly inform the (SFS) of the situation and request SFS manually update the records directly in the NSLDS. The OUR will implement this change to internal controls going forward, knowing that this represents additional manual monitoring and action. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.
2024-003
FAC accepted this audit on March 9, 2025 — management decision was due September 9, 2025.
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. Additionally, the University is working with external consultants to enhance financial aid processing systems. This will gain efficiencies to ensure data is reported within the required timeframes. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.
2023-003
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. The University has opened multiple positions within the department to enhance efficiency. All current staff will be trained on a continuous basis to ensure knowledge of compliance. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students' eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. The University has already hired multiple positions and had various training courses in order to enhance knowledge of compliance. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Working with University staff to enhance the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE's ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. With the financial aid office now near full staffing, we have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. Any rejected records will be resolved and resubmitted with the same timeframe. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
Criteria: 2 CFR 200.431 includes the standards for documentation of fringe benefits. According to 2 CFR 200.431(c), the cost of fringe benefits are allowable, provided such benefits are granted under established written policies. Such benefits should be charged as direct or indirect costs in accordance with the non-Federal entity’s accounting practices. Additionally, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted several conditions that existed due to cost transfers that occurred during the fiscal year. While performing procedures related to cost transfers, we noted the University had not followed their ‘Cost Transfer Policy’ which states “Cost transfers for current transactions must occur on a timely basis”. The University’s cost transfer policy defines timely as “occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)”. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted seventy-five of our one hundred nineteen transactions sampled cost transfers (totaling $246,869 positive and $66,004 negative) where the cost transfer date was between 91 and 1,002 days past the date the original expenditure was incurred (30 were between 91 and 180 days past, 15 were between 181 and 270 days past, and 30 were greater than 271 days past). While testing cost transfers and adjustments, we noted a transaction recorded to a grant that did not have supporting documentation resulting in the costs being unallowable to the grant: Additionally, we noted a transaction recorded to a grant that was recorded outside of the period of performance resulting in the costs being unallowable to the grant: During the fiscal year, positive cost transfers were approximately $2,815,865 and negative cost transfers were $1,792,678 during fiscal year 2023. While performing procedures related to fringe benefits, we noted one of twenty-five sampled grants (totaling $461,382) where transactions were originally recorded to an incorrect worktag. Management identified the error and a cost transfer was performed to move the fringe benefits to a federal research and development grant. However, the incorrect fringe rate was utilized as the University’s non-sponsored research fringe rate utilized in the original entry is a higher fringe rate than the federally approved fringe rate which resulted in an overcharge to the research and development grant during the University’s fiscal year ended June 30, 2023 for a total overstatement of $26 as noted below: Additionally, we noted fringe benefits were expensed during the University’s fiscal year ended June 30, 2023 for two of twenty-five sampled grants (totaling $461,382) where the labor transaction originated in previous fiscal years. The University booked an adjustment within Workday to correct the fringe benefit charges for the life of the grant. This resulted in the SEFA being overstated during the University’s fiscal year ended June 30, 2023. We noted the total fringe benefits charged for the life of the grants was allowable and within the period of performance. These overstatements to the SEFA for the University’s fiscal year 2023 was for a total of $3,134 as noted below: Total fringe benefits during fiscal year 2023 totaled approximately $2,673,231.While performing procedures related to indirect costs, we noted indirect costs were expensed during the University’s fiscal year ended June 30, 2023 for two of forty sampled grants (totaling $1,817,264) where indirect costs were originally undercharged during the previous fiscal year. The University booked an adjustment within Workday to correct the indirect costs for the life of the grant. This resulted in the SEFA being overstated during the University’s fiscal year ended June 30, 2023. We noted the total indirect costs charged for the life of the grants was allowable and within the period of performance. These overstatements to the SEFA for the University’s fiscal year 2023 was for a total of $3,677 as noted below: Total indirect costs during fiscal year 2023 totaled approximately $10,484,419. Questioned Cost: Known questioned costs of $26. Cause and Effect: In discussing these conditions with University management, they stated that during fiscal year 2023, they continued reconciliation procedures related to ‘grant level’ activity as a result of implementing the grants module of Workday during fiscal year 2021. Grant level activity allows them to track the specific budget provided by the individual grant as well as monitor other key compliance requirement aspects. The University continued to process an increased volume of cost transfers and experienced delays in posting necessary cost transfers for identified unallowable costs stemming from the reconciliation efforts. Repeat Finding: A similar finding was reported in prior year audit as finding number 2022-001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University continue its corrective action plan and adjust internal controls as needed to prevent and detect noncompliance with and improve adherence to federal regulations.View of Responsible Official: The University concurs with the finding. As noted in our prior year response, the University continued to have cost transfers in fiscal year 2023 as it reconciled its grants. To limit cost transfers in the future, the following steps have been taken by the University: Additionally, the University is exploring additional functionality within our Workday grants management module to build in additional approvals, specifically for labor, on expense before the expenses are charged to the grant to reduce future cost transfers. In regards to the three transactions noted above (federal award number HHSN272201300021I; federal award number 5R21AG065526-02; and federal award number UH3HD096929), the erroneous charges have been refunded to the federal agency. As part of the University’s corrective action plan, during fiscal year 2023 the sponsored programs accounting team recalculated fringe and indirect costs on all federal grants to ensure the correct expense was recorded to each grant. During this reconciliation process cumulative award to date errors were identified and corrected in fiscal year 2023. The sponsored program accounting team continues to reconcile fringe and indirect costs on cost transfers at the grant level on a periodic basis to ensure accuracy.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR 200.431 includes the standards for documentation of fringe benefits. According to 2 CFR 200.431(c), the cost of fringe benefits are allowable, provided such benefits are granted under established written policies. Such benefits should be charged as direct or indirect costs in accordance with the non-Federal entity’s accounting practices. Additionally, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted several conditions that existed due to cost transfers that occurred during the fiscal year. While performing procedures related to cost transfers, we noted the University had not followed their ‘Cost Transfer Policy’ which states “Cost transfers for current transactions must occur on a timely basis”. The University’s cost transfer policy defines timely as “occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)”. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted seventy-five of our one hundred nineteen transactions sampled cost transfers (totaling $246,869 positive and $66,004 negative) where the cost transfer date was between 91 and 1,002 days past the date the original expenditure was incurred (30 were between 91 and 180 days past, 15 were between 181 and 270 days past, and 30 were greater than 271 days past). While testing cost transfers and adjustments, we noted a transaction recorded to a grant that did not have supporting documentation resulting in the costs being unallowable to the grant: Additionally, we noted a transaction recorded to a grant that was recorded outside of the period of performance resulting in the costs being unallowable to the grant: During the fiscal year, positive cost transfers were approximately $2,815,865 and negative cost transfers were $1,792,678 during fiscal year 2023. While performing procedures related to fringe benefits, we noted one of twenty-five sampled grants (totaling $461,382) where transactions were originally recorded to an incorrect worktag. Management identified the error and a cost transfer was performed to move the fringe benefits to a federal research and development grant. However, the incorrect fringe rate was utilized as the University’s non-sponsored research fringe rate utilized in the original entry is a higher fringe rate than the federally approved fringe rate which resulted in an overcharge to the research and development grant during the University’s fiscal year ended June 30, 2023 for a total overstatement of $26 as noted below: Additionally, we noted fringe benefits were expensed during the University’s fiscal year ended June 30, 2023 for two of twenty-five sampled grants (totaling $461,382) where the labor transaction originated in previous fiscal years. The University booked an adjustment within Workday to correct the fringe benefit charges for the life of the grant. This resulted in the SEFA being overstated during the University’s fiscal year ended June 30, 2023. We noted the total fringe benefits charged for the life of the grants was allowable and within the period of performance. These overstatements to the SEFA for the University’s fiscal year 2023 was for a total of $3,134 as noted below: Total fringe benefits during fiscal year 2023 totaled approximately $2,673,231.While performing procedures related to indirect costs, we noted indirect costs were expensed during the University’s fiscal year ended June 30, 2023 for two of forty sampled grants (totaling $1,817,264) where indirect costs were originally undercharged during the previous fiscal year. The University booked an adjustment within Workday to correct the indirect costs for the life of the grant. This resulted in the SEFA being overstated during the University’s fiscal year ended June 30, 2023. We noted the total indirect costs charged for the life of the grants was allowable and within the period of performance. These overstatements to the SEFA for the University’s fiscal year 2023 was for a total of $3,677 as noted below: Total indirect costs during fiscal year 2023 totaled approximately $10,484,419. Questioned Cost: Known questioned costs of $26. Cause and Effect: In discussing these conditions with University management, they stated that during fiscal year 2023, they continued reconciliation procedures related to ‘grant level’ activity as a result of implementing the grants module of Workday during fiscal year 2021. Grant level activity allows them to track the specific budget provided by the individual grant as well as monitor other key compliance requirement aspects. The University continued to process an increased volume of cost transfers and experienced delays in posting necessary cost transfers for identified unallowable costs stemming from the reconciliation efforts. Repeat Finding: A similar finding was reported in prior year audit as finding number 2022-001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University continue its corrective action plan and adjust internal controls as needed to prevent and detect noncompliance with and improve adherence to federal regulations.View of Responsible Official: The University concurs with the finding. As noted in our prior year response, the University continued to have cost transfers in fiscal year 2023 as it reconciled its grants. To limit cost transfers in the future, the following steps have been taken by the University: Additionally, the University is exploring additional functionality within our Workday grants management module to build in additional approvals, specifically for labor, on expense before the expenses are charged to the grant to reduce future cost transfers. In regards to the three transactions noted above (federal award number HHSN272201300021I; federal award number 5R21AG065526-02; and federal award number UH3HD096929), the erroneous charges have been refunded to the federal agency. As part of the University’s corrective action plan, during fiscal year 2023 the sponsored programs accounting team recalculated fringe and indirect costs on all federal grants to ensure the correct expense was recorded to each grant. During this reconciliation process cumulative award to date errors were identified and corrected in fiscal year 2023. The sponsored program accounting team continues to reconcile fringe and indirect costs on cost transfers at the grant level on a periodic basis to ensure accuracy.
As noted in our prior year response, the University continued to have cost transfers in fiscal year 2023 as it reconciled its grants. To limit cost transfers in the future, the following steps have been taken by the University: • The Controller’s Office along with the Office of the Vice President of Research configured our accounting system with an automated control that prevents general (non-payroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. • For payroll expenditures, post-award specialists updated grant labor costing allocations in our accounting system to contain an end date that coincides with the period of performance end date. This change in Workday restricts labor costs from being charged after the period of performance. The University’s post-award specialist review grant labor costing allocations on a periodic basis. • With collaboration between the payroll department, the Controller’s Office and post-award specialists, before each payroll is processed within the accounting system, grants that have ended are identified and the payroll expenditures are removed from the feed and not charged to the grant. • On-going training on data certification by post-award grant managers has improved grant-expenditure compliance and data accuracy. In addition, the Controller’s Office implemented a process in which post-award grant managers are now reviewing grant level budget versus actual reporting on a periodic basis to identify errors timely (i.e. before the 90 day threshold). Additionally, the University’s Workday team is exploring additional functionality within our Workday grants management module to build in additional expense approvals, specifically for labor, before those expenses are charged to the grant to reduce future cost transfers. As part of the University’s corrective action plan, during fiscal year 2023 the sponsored programs accounting team recalculated fringe and indirect costs on all federal grants to ensure the correct expense was recorded to each grant. During this reconciliation process cumulative award to date errors were identified and corrected. The sponsored program accounting team continues to reconcile fringe and indirect costs on cost transfers at the grant level on a periodic basis to ensure accuracy. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by June 2024.
2022-001
Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS-2). An accurate DS-2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS-2. Amendments to the DS-2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS-2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University’s last submitted DS-2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS-2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University’s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS-2. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in a revised DS-2 not being prepared and submitted. Repeat Finding: A similar finding was reported in prior year audit as finding number 2022-002. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS-2 are met. We recommend the University perform a thorough review of their existing DS-2 and determine what adjustments to the existing DS-2 are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS-2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS-2 prior to any amendments being submitted. View of Responsible Official: The University concurs with the finding. The University updated its DS-2 form and submitted it electronically to the U.S. Department of Health and Human Services on December 4, 2023. The Controller’s Office implemented an annual review of the DS-2 to identify factors that may require amendments to our next filing. In addition, prior to our submission of any DS-2 amendments, University staff other than the initial preparer will re-confirm the accuracy of changes to the DS-2.
Show full finding ▾Hide full finding ▴Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS-2). An accurate DS-2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS-2. Amendments to the DS-2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS-2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University’s last submitted DS-2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS-2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University’s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS-2. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in a revised DS-2 not being prepared and submitted. Repeat Finding: A similar finding was reported in prior year audit as finding number 2022-002. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS-2 are met. We recommend the University perform a thorough review of their existing DS-2 and determine what adjustments to the existing DS-2 are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS-2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS-2 prior to any amendments being submitted. View of Responsible Official: The University concurs with the finding. The University updated its DS-2 form and submitted it electronically to the U.S. Department of Health and Human Services on December 4, 2023. The Controller’s Office implemented an annual review of the DS-2 to identify factors that may require amendments to our next filing. In addition, prior to our submission of any DS-2 amendments, University staff other than the initial preparer will re-confirm the accuracy of changes to the DS-2.
The University updated its DS-2 form and submitted it electronically to the U.S. Department of Health and Human Services on December 4, 2023. The Controller’s Office implemented an annual review of the DS-2 to identify factors that may require amendments to our next filing. In addition, prior to our submission of any DS-2 amendments, University staff other than the initial preparer will re-confirm the accuracy of changes to the DS-2. Tara Thomason, Controller and Assistance Vice President, was responsible for addressing the above.
2022-002
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure Direct Loan and Pell Grant disbursement records are submitted to the COD no later than 15 days after making the disbursement. For one of fifty-six Direct Loan disbursement samples, the University did not submit the Direct Loan disbursement record to the COD. For one of four Pell Grant disbursement samples where the University submitted the Pell Grant disbursement record to the COD 27 days after the disbursement date which was not within the 15-day requirement. Management provided a report comparing all disbursements of Direct Loan and Pell during fiscal year 2023 compared to the reporting to the COD. This report shows noncompliance of 759 Pell Grant disbursements submitted late out of 5,708 (13% of population) total Pell Grant disbursements and 255 Direct Loan disbursements submitted late or not submitted as of August 14, 2023 out of 21,130 (1% of the population) total Direct Loan disbursements. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues to resolve reports that were not accepted based on the original submission resulted in reporting disbursement record reports to the COD later than the 15-day requirement. Repeat Finding: A similar finding was reported in prior year as finding number 2022-008. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure Direct Loan and Pell Grant disbursement records are submitted or records that were not accepted based on the original submission are resolved and resubmitted to COD no later than 15-days after making the disbursement. View of Responsible Official: We acknowledge the deficiencies identified in our internal control process, specifically regarding the submission of Direct Loan and Pell Grant disbursement records to COD within the prescribed 15-day timeframe. The instances highlighted in this report, particularly the delayed submission of records for one Direct Loan disbursement sample and one Pell Grant disbursement sample, are indicative of areas where improvement is necessary. We provided insights into the root cause, citing capacity issues in addressing reports that were initially rejected, leading to delays in resubmission. While this explanation sheds light on the challenges faced, it underscores the importance of fortifying our internal control mechanisms to mitigate such delays in the future. Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance.
Show full finding ▾Hide full finding ▴Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure Direct Loan and Pell Grant disbursement records are submitted to the COD no later than 15 days after making the disbursement. For one of fifty-six Direct Loan disbursement samples, the University did not submit the Direct Loan disbursement record to the COD. For one of four Pell Grant disbursement samples where the University submitted the Pell Grant disbursement record to the COD 27 days after the disbursement date which was not within the 15-day requirement. Management provided a report comparing all disbursements of Direct Loan and Pell during fiscal year 2023 compared to the reporting to the COD. This report shows noncompliance of 759 Pell Grant disbursements submitted late out of 5,708 (13% of population) total Pell Grant disbursements and 255 Direct Loan disbursements submitted late or not submitted as of August 14, 2023 out of 21,130 (1% of the population) total Direct Loan disbursements. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues to resolve reports that were not accepted based on the original submission resulted in reporting disbursement record reports to the COD later than the 15-day requirement. Repeat Finding: A similar finding was reported in prior year as finding number 2022-008. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure Direct Loan and Pell Grant disbursement records are submitted or records that were not accepted based on the original submission are resolved and resubmitted to COD no later than 15-days after making the disbursement. View of Responsible Official: We acknowledge the deficiencies identified in our internal control process, specifically regarding the submission of Direct Loan and Pell Grant disbursement records to COD within the prescribed 15-day timeframe. The instances highlighted in this report, particularly the delayed submission of records for one Direct Loan disbursement sample and one Pell Grant disbursement sample, are indicative of areas where improvement is necessary. We provided insights into the root cause, citing capacity issues in addressing reports that were initially rejected, leading to delays in resubmission. While this explanation sheds light on the challenges faced, it underscores the importance of fortifying our internal control mechanisms to mitigate such delays in the future. Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance.
Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.
2022-008
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
Finding 2022 001 Federal Program Title ? Research & Development Cluster (R&D) Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Also, the HHS Grants Policy for educational institutions requires a plan confirmation system (system) for professorial and other professional staff members that is based on budgeted, planned, or assigned work activity and that is updated to reflect any significant changes in work distribution. The system must be incorporated into the organization?s official records and must identify activity applicable to each sponsored agreement and to each category needed to identify indirect costs and the functions to which they are allocable. At least annually, the employee, principal investigator, or responsible official will verify, by suitable means, that the work was performed and that the salaries and wages charged to sponsored agreements, whether as direct charges or in other categories of cost, are reasonable in relation to the work performed. A system, supported by after-the-fact activity reports, that reflects the distribution of covered employees? activity allocable to each grant and includes identification and recording of significant changes in work activity when initial charges were based on estimates. For professorial and other professional staff members, the activity reports will be prepared each academic term, but at least every 6 months. The University?s `Effort Reporting Policy? states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? Additionally, as set forth in 2 CFR 200, the University is required to ensure allowable costs do not consist of improper payments, including payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments). Indirect costs are required to adhere to 2 CFR 200, Appendix III. Further, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing procedures related to personnel expenses, we noted the University had not followed their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted two of our sixty sampled effort reports that had not been returned within the 30-calendar day policy. Total payroll and fringe totaled approximately $13,200,000 during fiscal year 2022. While performing procedures related to indirect costs, we noted three of forty sampled grants (totaling $3,385,750) where transactions were originally recorded to an incorrect object class that resulted in F&A being applied to the grant instead of to the correct object class which resulted in overcharges during the University?s fiscal year ended June 30, 2022 for a total overstatement of $1,888 as noted below: See Schedule of Findings and Questioned Costs for chart/table Additionally, we noted indirect costs were overcharged for two of forty sampled grants (totaling $3,385,750) where transactions were originally recorded to an incorrect object class during the University?s fiscal year ended June 30, 2021 that resulted in F&A being applied to the grant instead of to the correct object class which resulted in overcharges. These overstatements were corrected during the University?s fiscal year ended June 30, 2022 for a total of $18,377 as noted below: See Schedule of Findings and Questioned Costs for chart/table Total indirect costs during fiscal year 2022 totaled approximately $8,360,000. While performing procedures related to cost transfers, we noted the University had not followed their `Cost Transfer Policy? which states ?Cost transfers for current transactions must occur on a timely basis?. The University?s cost transfer policy defines timely as ?occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)?. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted thirty-two of our sixty-seven sampled cost transfers (totaling $3,153,441 positive and $2,900,348 negative) where the cost transfer date was between 91 and 581 days past the date the original expenditure was incurred (21 were between 91 and 180 days past, 6 were between 181 and 270 days past, and 5 were greater than 271 days past). While testing cost transfers, we noted the following exceptions: We noted a transaction which was originally recorded to an incorrect object class that resulted in F&A being applied to the grant instead of to the correct object class that did not allow F&A costs to be applied: See Schedule of Findings and Questioned Costs for chart/table Additionally, we noted a transaction recorded to a grant that exceeded the amount of the award resulting in the costs being unallowable to the grant: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers were approximately $4,060,000 and negative cost transfers were $3,510,000 during fiscal year 2022. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated that during fiscal year 2022, they continued reconciliation procedures related to `grant level? activity as a result of implementing the grants module of Workday in the previous fiscal year. Grant level activity allows them to track the specific budget provided by the individual R&D Cluster agreement as well as monitor other key compliance requirement aspects. The University continued to process an increased volume of cost transfers and experienced delays in posting necessary cost transfers for identified unallowable costs stemming from the reconciliation efforts. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at its processes, policies and internal controls to determine what is needed, post Workday implementation, to prevent and detect noncompliance with activities allowed and unallowed and adherence to allowable cost principles/cost principles. Additionally, we recommend the University determine and address the underlying root cause that is contributing to the volume of cost transfers and take necessary action to prevent unallowable costs from posting to the grant. We also recommend the University consider implementation of an automated control to ensure F&A is charged appropriately when cost transfer entries are made. Lastly, we recommend the University determine what additional Workday automated reporting is available to monitor compliance for personnel expenses, including effort verification reporting, F&A, etc. for activities allowed or unallowed and allowable costs/cost principles.
Show full finding ▾Hide full finding ▴Finding 2022 001 Federal Program Title ? Research & Development Cluster (R&D) Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Also, the HHS Grants Policy for educational institutions requires a plan confirmation system (system) for professorial and other professional staff members that is based on budgeted, planned, or assigned work activity and that is updated to reflect any significant changes in work distribution. The system must be incorporated into the organization?s official records and must identify activity applicable to each sponsored agreement and to each category needed to identify indirect costs and the functions to which they are allocable. At least annually, the employee, principal investigator, or responsible official will verify, by suitable means, that the work was performed and that the salaries and wages charged to sponsored agreements, whether as direct charges or in other categories of cost, are reasonable in relation to the work performed. A system, supported by after-the-fact activity reports, that reflects the distribution of covered employees? activity allocable to each grant and includes identification and recording of significant changes in work activity when initial charges were based on estimates. For professorial and other professional staff members, the activity reports will be prepared each academic term, but at least every 6 months. The University?s `Effort Reporting Policy? states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? Additionally, as set forth in 2 CFR 200, the University is required to ensure allowable costs do not consist of improper payments, including payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments). Indirect costs are required to adhere to 2 CFR 200, Appendix III. Further, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing procedures related to personnel expenses, we noted the University had not followed their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted two of our sixty sampled effort reports that had not been returned within the 30-calendar day policy. Total payroll and fringe totaled approximately $13,200,000 during fiscal year 2022. While performing procedures related to indirect costs, we noted three of forty sampled grants (totaling $3,385,750) where transactions were originally recorded to an incorrect object class that resulted in F&A being applied to the grant instead of to the correct object class which resulted in overcharges during the University?s fiscal year ended June 30, 2022 for a total overstatement of $1,888 as noted below: See Schedule of Findings and Questioned Costs for chart/table Additionally, we noted indirect costs were overcharged for two of forty sampled grants (totaling $3,385,750) where transactions were originally recorded to an incorrect object class during the University?s fiscal year ended June 30, 2021 that resulted in F&A being applied to the grant instead of to the correct object class which resulted in overcharges. These overstatements were corrected during the University?s fiscal year ended June 30, 2022 for a total of $18,377 as noted below: See Schedule of Findings and Questioned Costs for chart/table Total indirect costs during fiscal year 2022 totaled approximately $8,360,000. While performing procedures related to cost transfers, we noted the University had not followed their `Cost Transfer Policy? which states ?Cost transfers for current transactions must occur on a timely basis?. The University?s cost transfer policy defines timely as ?occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)?. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted thirty-two of our sixty-seven sampled cost transfers (totaling $3,153,441 positive and $2,900,348 negative) where the cost transfer date was between 91 and 581 days past the date the original expenditure was incurred (21 were between 91 and 180 days past, 6 were between 181 and 270 days past, and 5 were greater than 271 days past). While testing cost transfers, we noted the following exceptions: We noted a transaction which was originally recorded to an incorrect object class that resulted in F&A being applied to the grant instead of to the correct object class that did not allow F&A costs to be applied: See Schedule of Findings and Questioned Costs for chart/table Additionally, we noted a transaction recorded to a grant that exceeded the amount of the award resulting in the costs being unallowable to the grant: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers were approximately $4,060,000 and negative cost transfers were $3,510,000 during fiscal year 2022. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated that during fiscal year 2022, they continued reconciliation procedures related to `grant level? activity as a result of implementing the grants module of Workday in the previous fiscal year. Grant level activity allows them to track the specific budget provided by the individual R&D Cluster agreement as well as monitor other key compliance requirement aspects. The University continued to process an increased volume of cost transfers and experienced delays in posting necessary cost transfers for identified unallowable costs stemming from the reconciliation efforts. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at its processes, policies and internal controls to determine what is needed, post Workday implementation, to prevent and detect noncompliance with activities allowed and unallowed and adherence to allowable cost principles/cost principles. Additionally, we recommend the University determine and address the underlying root cause that is contributing to the volume of cost transfers and take necessary action to prevent unallowable costs from posting to the grant. We also recommend the University consider implementation of an automated control to ensure F&A is charged appropriately when cost transfer entries are made. Lastly, we recommend the University determine what additional Workday automated reporting is available to monitor compliance for personnel expenses, including effort verification reporting, F&A, etc. for activities allowed or unallowed and allowable costs/cost principles.
The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. The Controller?s Office will review its indirect costs configurations within the grants module of Workday to ensure the automated calculation of indirect costs is correct. In addition, the Sponsored Programs Accounting team will manually reconcile indirect costs periodically at the grant level. These improvements are expected to be completed by December 2023. The University continues to have cost transfers in fiscal year 2023 as it reconciles its grants. However, to limit cost transfers in the future, the Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (non-payroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
2021-001
Federal Program Titles ? Research & Development Cluster and COVID 19 National Organizations of State and Local Officials Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards for R&D Cluster 93.011 ? COVID 19 National Organizations of State and Local Officials Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various for Research & Development Cluster and June 1, 2021 to August 31, 2022 and July 31, 2021 to October 31, 2022, for COVID 19 National Organizations of State and Local Officials Compliance Requirements ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS 2). An accurate DS 2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS 2. Amendments to the DS 2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS 2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University?s last submitted DS 2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS 2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University?s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS 2. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in the a revised DS 2 not being prepared and submitted. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 002. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS 2 are met. We recommend the University perform a thorough review of their existing DS 2 and determine what adjustments to the existing D2-2 are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS 2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS 2 prior to any amendments being submitted.
Show full finding ▾Hide full finding ▴Federal Program Titles ? Research & Development Cluster and COVID 19 National Organizations of State and Local Officials Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards for R&D Cluster 93.011 ? COVID 19 National Organizations of State and Local Officials Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various for Research & Development Cluster and June 1, 2021 to August 31, 2022 and July 31, 2021 to October 31, 2022, for COVID 19 National Organizations of State and Local Officials Compliance Requirements ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS 2). An accurate DS 2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS 2. Amendments to the DS 2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS 2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University?s last submitted DS 2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS 2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University?s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS 2. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in the a revised DS 2 not being prepared and submitted. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 002. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS 2 are met. We recommend the University perform a thorough review of their existing DS 2 and determine what adjustments to the existing D2-2 are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS 2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS 2 prior to any amendments being submitted.
The Controller?s office will implement an annual review process of the DS-2, which will include someone other than the preparer performing a review of the DS-2 prior to amendments being submitted. The first review will be completed by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
2021-002
Finding 2022 003 Federal Program Title ? Research & Development Cluster Assistance Listing No. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Equipment/Real Property Management Criteria: As set forth in 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to the accuracy and completeness of property records and physical inspection of the existence and safeguarding of fifty-seven equipment items (with a net book value of 628,232), the following conditions were identified: ? During our physical inspection procedures, which took several attempts, we noted thirty-five equipment items sampled (with a net book value of $583,715) that were not found at the location stated within the fiscal year 2022 property records maintained by the University for the following items: See Schedule of Findings and Questioned Costs for chart/table The property records for ten equipment items sampled (with a net book value of $327,266) did not have accurate property records (note some of these same equipment items were also not found at the location stated and were also included in the table above). Specifically, the serial number on the equipment item sampled was not documented in the fiscal year 2022 property records maintained by the University for the following items: See Schedule of Findings and Questioned Costs for chart/table ? The property records for two equipment items (with $0 net book value) sampled were not updated to reflect disposals made during fiscal year 2022. Management stated no proceeds were received for the following items: See Schedule of Findings and Questioned Costs for chart/table The University did not have an effective system of internal control in place to ensure property records accurately reflect equipment locations, equipment serial numbers, and disposals. As of June 30, 2022, the University was responsible for maintaining and safeguarding equipment purchased using federal awards with a net book value of $2,110,646. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that inadequate documentation of policies and procedures regarding the types of conditions that require communication to the Business and Finance office (e.g., when equipment is moved to a different location), as well as a lack of a review of changes made to property records by someone other than the preparer, contributed to multiple errors in the property records. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen policies, procedures and internal controls to ensure requirements around equipment/real property management are met. We recommend the University perform a detailed review of the property records and make corrections to accurately reflect the required information. We also recommend the University take a fresh look at their capital equipment recordkeeping policies and procedures and consider both preventive and detective internal controls to ensure property records accurately reflect the requirements of 2 CFR 200.313(d)(1).
Show full finding ▾Hide full finding ▴Finding 2022 003 Federal Program Title ? Research & Development Cluster Assistance Listing No. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Equipment/Real Property Management Criteria: As set forth in 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to the accuracy and completeness of property records and physical inspection of the existence and safeguarding of fifty-seven equipment items (with a net book value of 628,232), the following conditions were identified: ? During our physical inspection procedures, which took several attempts, we noted thirty-five equipment items sampled (with a net book value of $583,715) that were not found at the location stated within the fiscal year 2022 property records maintained by the University for the following items: See Schedule of Findings and Questioned Costs for chart/table The property records for ten equipment items sampled (with a net book value of $327,266) did not have accurate property records (note some of these same equipment items were also not found at the location stated and were also included in the table above). Specifically, the serial number on the equipment item sampled was not documented in the fiscal year 2022 property records maintained by the University for the following items: See Schedule of Findings and Questioned Costs for chart/table ? The property records for two equipment items (with $0 net book value) sampled were not updated to reflect disposals made during fiscal year 2022. Management stated no proceeds were received for the following items: See Schedule of Findings and Questioned Costs for chart/table The University did not have an effective system of internal control in place to ensure property records accurately reflect equipment locations, equipment serial numbers, and disposals. As of June 30, 2022, the University was responsible for maintaining and safeguarding equipment purchased using federal awards with a net book value of $2,110,646. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that inadequate documentation of policies and procedures regarding the types of conditions that require communication to the Business and Finance office (e.g., when equipment is moved to a different location), as well as a lack of a review of changes made to property records by someone other than the preparer, contributed to multiple errors in the property records. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen policies, procedures and internal controls to ensure requirements around equipment/real property management are met. We recommend the University perform a detailed review of the property records and make corrections to accurately reflect the required information. We also recommend the University take a fresh look at their capital equipment recordkeeping policies and procedures and consider both preventive and detective internal controls to ensure property records accurately reflect the requirements of 2 CFR 200.313(d)(1).
The Controller?s Office is amending our capital equipment policy to include the escalation for violations of noncompliance to Deans and/or Vice Presidents. In addition, we are improving our processes and internal controls to ensure additions, transfers and disposals are appropriately recorded in Workday. We continue to improve our utilization of Workday Financials to ensure timely updates are made to the property records and are exploring additional automation tools. These changes are expected to be in place by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
2021-003
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.
Show full finding ▾Hide full finding ▴Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.
The Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (nonpayroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
2021-004
Finding 2022-005 Federal Program Title ? COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing No. ? 84.425F Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Number ? Not applicable Grant Award Period ? April 22, 2020 through January 17, 2022 Compliance Requirement ? Reporting Criteria: As set forth in 34 CFR 75.720(b), all HEERF grantees must submit a Higher Education Emergency Relief Fund (HEERF) Annual Report. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure the HEERF Annual Report was reviewed by someone other than the preparer for completeness and accuracy prior to submission to the U.S. Department of Education. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control to ensure the required Annual Report submitted to the U.S. Department of Education was reviewed by someone other than the preparer for completeness and accuracy. The lack of a review by someone other than the preparer could result in information being reported that is materially inaccurate or incomplete. Repeat Finding: A similar finding regarding internal control was reported in prior year audits as finding numbers 2020-001 and 2021-005. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure the required reports are reviewed by someone other than the preparer for completeness and accuracy prior to being submitted to the U.S. Department of Education.
Show full finding ▾Hide full finding ▴Finding 2022-005 Federal Program Title ? COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing No. ? 84.425F Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Number ? Not applicable Grant Award Period ? April 22, 2020 through January 17, 2022 Compliance Requirement ? Reporting Criteria: As set forth in 34 CFR 75.720(b), all HEERF grantees must submit a Higher Education Emergency Relief Fund (HEERF) Annual Report. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure the HEERF Annual Report was reviewed by someone other than the preparer for completeness and accuracy prior to submission to the U.S. Department of Education. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control to ensure the required Annual Report submitted to the U.S. Department of Education was reviewed by someone other than the preparer for completeness and accuracy. The lack of a review by someone other than the preparer could result in information being reported that is materially inaccurate or incomplete. Repeat Finding: A similar finding regarding internal control was reported in prior year audits as finding numbers 2020-001 and 2021-005. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure the required reports are reviewed by someone other than the preparer for completeness and accuracy prior to being submitted to the U.S. Department of Education.
The Controller?s office will collaborate with the necessary teams across the University to ensure the required reports are reviewed by someone other than the preparer to ensure completeness and accuracy prior to being submitted to the U.S. Department of Education. This is expected to be completed by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
2021-005
Finding 2022 006 Federal Program Title ? COVID-19 ? Provider Relief Fund and American Rescue Plan Rural Distribution Assistance Listing No. ? 93.498 Federal Agencies ? U.S. Department of Health and Human Services Federal Award Number ? Not applicable Grant Award Period ? January 1, 2020 to June 30, 2022 Compliance Requirement ? Reporting Criteria: Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR Section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal and the PRF period 3 report contains key line items. Key line items, when calculating lost revenues based on 2019 actuals, consist of the following which are required to be completely and accurately reported: 1) Total revenue/net charges for each quarter; and 2) Each cell by payer for each quarter (i.e., Medicare A+B, Medicare C, Children?s Health Insurance Program/CHIP, Commercial Insurance, Self-Pay, and Other). Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing for the reporting compliance requirement, the following conditions were identified: ? Total revenue/net charges from patient care attributable to quarter two (Q2) 2021 actuals for Self-Pay (No Insurance) was understated by $2,000,000. Total revenue/net charges from patient care attributable to Q2 2021 actuals for Self-Pay (No Insurance) per the PRF period 3 report noted $3,758,128 and the supporting documentation provided by the University reported $5,758,128. This $2,000,000 error occurred in a quarter that did not result in lost revenue. ? The period 3 report which included actuals for calendar years 2019 through 2021, reported $6,754,185 as Commercial Insurance which included "Charge Corrections" made by the University. The Charge Corrections represented corrections made across all payer categories but the entire amount was reported within Commercial Insurance. As a result, the amounts reported for the Commercial Insurance payer category was overstated for each of the quarters in calendar years 2019 through 2021 and all other payer categories were understated for each of the quarters. ? For Q3 2021 and Q4 2021, the PRF period 3 report included allocations of "Charge Corrections" and a reclassification made by the University in the amount of $6,177,240. The Charge Corrections and the reclassification impacted three payer categories: Medicaid/Children?s Health Insurance Program of $4,533,665; Medicare A+B of $1,000,000; and Other of $643,575. ? For Q1 2022 and Q2 2022, the PRF period 3 report included $61,431 for the Commercial Insurance payer category than what was supported by the detail and the Other payer category included $61,431 less than what was supported by the detail. The University did not have an effective system of internal control in place to ensure that key line items within the PRF period 3 report were complete and accurate. Questioned Cost: There are no questioned costs as the University had excess lost revenues greater than their period 3 PRF award. Cause and Effect: In discussing these conditions with University management, they stated that an effective system of internal controls to ensure the completeness and accuracy of amounts reported within the period 3 PRF report did not exist and resulted in certain key line items as listed above being inaccurate. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place that includes a review of all amounts, including all key line items, allocations and reclassifications within the PRF report to determine completeness and accuracy before submission into the portal.
Show full finding ▾Hide full finding ▴Finding 2022 006 Federal Program Title ? COVID-19 ? Provider Relief Fund and American Rescue Plan Rural Distribution Assistance Listing No. ? 93.498 Federal Agencies ? U.S. Department of Health and Human Services Federal Award Number ? Not applicable Grant Award Period ? January 1, 2020 to June 30, 2022 Compliance Requirement ? Reporting Criteria: Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR Section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal and the PRF period 3 report contains key line items. Key line items, when calculating lost revenues based on 2019 actuals, consist of the following which are required to be completely and accurately reported: 1) Total revenue/net charges for each quarter; and 2) Each cell by payer for each quarter (i.e., Medicare A+B, Medicare C, Children?s Health Insurance Program/CHIP, Commercial Insurance, Self-Pay, and Other). Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing for the reporting compliance requirement, the following conditions were identified: ? Total revenue/net charges from patient care attributable to quarter two (Q2) 2021 actuals for Self-Pay (No Insurance) was understated by $2,000,000. Total revenue/net charges from patient care attributable to Q2 2021 actuals for Self-Pay (No Insurance) per the PRF period 3 report noted $3,758,128 and the supporting documentation provided by the University reported $5,758,128. This $2,000,000 error occurred in a quarter that did not result in lost revenue. ? The period 3 report which included actuals for calendar years 2019 through 2021, reported $6,754,185 as Commercial Insurance which included "Charge Corrections" made by the University. The Charge Corrections represented corrections made across all payer categories but the entire amount was reported within Commercial Insurance. As a result, the amounts reported for the Commercial Insurance payer category was overstated for each of the quarters in calendar years 2019 through 2021 and all other payer categories were understated for each of the quarters. ? For Q3 2021 and Q4 2021, the PRF period 3 report included allocations of "Charge Corrections" and a reclassification made by the University in the amount of $6,177,240. The Charge Corrections and the reclassification impacted three payer categories: Medicaid/Children?s Health Insurance Program of $4,533,665; Medicare A+B of $1,000,000; and Other of $643,575. ? For Q1 2022 and Q2 2022, the PRF period 3 report included $61,431 for the Commercial Insurance payer category than what was supported by the detail and the Other payer category included $61,431 less than what was supported by the detail. The University did not have an effective system of internal control in place to ensure that key line items within the PRF period 3 report were complete and accurate. Questioned Cost: There are no questioned costs as the University had excess lost revenues greater than their period 3 PRF award. Cause and Effect: In discussing these conditions with University management, they stated that an effective system of internal controls to ensure the completeness and accuracy of amounts reported within the period 3 PRF report did not exist and resulted in certain key line items as listed above being inaccurate. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place that includes a review of all amounts, including all key line items, allocations and reclassifications within the PRF report to determine completeness and accuracy before submission into the portal.
Two transaction level controls will be implemented. A review of the IDX payer class grouping will be performed to validate the allocation of the report used to enter the key line items and a separate review will be performed on the line-item data in the portal compared to the reports. These controls will address each financial line item in the portal; regardless of whether it contributes to the portal financial calculation. Tammy Burton, Associate Dean of School of Medicine, is responsible for addressing the above items by March 31, 2023.
Finding 2022 007 Federal Program Title ? Student Financial Assistance Cluster ? Federal Direct Student Loans Assistance Listing No. ? 84.268 Federal Agency ? U.S. Department of Education Federal Award Number ?P268K221755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Eligibility Criteria: In accordance with 34 CFR 685.203(a) and (b), for dependent undergraduate students (excluding dependent undergraduates whose parents are unable to borrow Direct PLUS Loans), the combined Direct Subsidized Loan and Direct Unsubsidized Loan annual limits are: $5,500 for dependent first-year undergraduates, not more than $3,500 of which may be subsidized; $6,500 for dependent second-year undergraduates, not more than $4,500 of which may be subsidized; $7,500 for dependent third-, fourth-, and fifth-year undergraduates, not more than $5,500 of which may be subsidized. Additionally, in accordance with 34 CFR 685.203(a) and (c), for independent undergraduate students (including dependent undergraduates whose parents are unable to borrow Direct PLUS Loans), the combined Direct Subsidized Loan and Direct Unsubsidized Loan annual limits are: $9,500 for dependent first-year undergraduates, not more than $3,500 of which may be subsidized; $10,500 for dependent second-year undergraduates, not more than $4,500 of which may be subsidized; $12,500 for dependent third-, fourth-, and fifth-year undergraduates, not more than $5,500 of which may be subsidized. Additionally, in accordance with 34 CFR 685.301(a)(4), a school may not originate a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan or a combination of loans, for an amount that exceeds the student?s estimated cost of attendance less the student?s estimated financial assistance for that period and in the case of a Direct Subsidized Loan, the borrower?s expected family contribution for that period. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure amounts disbursed to students were properly determined. While performing procedures related to financial aid disbursements made to sixty-one students (with disbursements sampled totaling $1,110,440), we found that for two disbursements sampled, the incorrect grade-level was utilized to calculate the students award limits resulting in Direct Subsidized Loans disbursed (total of $6,271 and $6,234 Direct Loans was disbursed) which exceeded the set limit by $1,942 and $953, for a total over award of $2,895. Additionally, while performing procedures over financial aid disbursements made to sixty-one students (with disbursements sampled totaling $1,110,440), specifically over cost of attendance, we identified eight students sampled where the cost of attendance per the student?s records was overstated which resulted in the following: ? For four students sampled, clerical errors within the students cost of attendance records were identified resulting in one student being over awarded $25 of Direct PLUS Loans (a total of $17,088 of Direct Loans was disbursed). Three students with clerical errors did not result in an over award status because the student awards were less than the amount of the original cost of attendance. ? For four students sampled, the student?s status was incorrectly defaulting to full-time when each should have been identified as `part-time? which resulted in two students having Direct Unsubsidized Loans being over awarded in the amounts of $3,200 and $452 ($9,401 of Direct Loans was disbursed for each of the two students) and one student having Direct Subsidized and Unsubsidized ($11,094 of Direct Loans was disbursed), being over awarded in the amount of $5,912 (note this sample also had the incorrect grade-level discussed above which additionally contributed to the over award). One student sampled with the incorrect student status did not result in an over award status because amounts of loans secured were less than the annual loan limits and part-time cost of attendance. Questioned Cost: $12,484 Cause and Effect: In discussing these conditions with University management, they stated that: 1) clerical errors occurred related to manual cost of attendance adjustments; 2) grade-level data with their student system incorrectly populating from the FAFSA on certain students who had missing grade levels; and 3) student status? incorrectly defaulting on summer students enrolled in a certificate program. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process related to eligibility and consider implementing management review controls when the cost of attendance is manually adjusted to have someone other than the preparer review the accuracy of the data entered. We also recommend the University consider whether configuring and generating additional routine exception reports could inform management of discrepancies that would detect errors which impact eligibility determinations.
Show full finding ▾Hide full finding ▴Finding 2022 007 Federal Program Title ? Student Financial Assistance Cluster ? Federal Direct Student Loans Assistance Listing No. ? 84.268 Federal Agency ? U.S. Department of Education Federal Award Number ?P268K221755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Eligibility Criteria: In accordance with 34 CFR 685.203(a) and (b), for dependent undergraduate students (excluding dependent undergraduates whose parents are unable to borrow Direct PLUS Loans), the combined Direct Subsidized Loan and Direct Unsubsidized Loan annual limits are: $5,500 for dependent first-year undergraduates, not more than $3,500 of which may be subsidized; $6,500 for dependent second-year undergraduates, not more than $4,500 of which may be subsidized; $7,500 for dependent third-, fourth-, and fifth-year undergraduates, not more than $5,500 of which may be subsidized. Additionally, in accordance with 34 CFR 685.203(a) and (c), for independent undergraduate students (including dependent undergraduates whose parents are unable to borrow Direct PLUS Loans), the combined Direct Subsidized Loan and Direct Unsubsidized Loan annual limits are: $9,500 for dependent first-year undergraduates, not more than $3,500 of which may be subsidized; $10,500 for dependent second-year undergraduates, not more than $4,500 of which may be subsidized; $12,500 for dependent third-, fourth-, and fifth-year undergraduates, not more than $5,500 of which may be subsidized. Additionally, in accordance with 34 CFR 685.301(a)(4), a school may not originate a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan or a combination of loans, for an amount that exceeds the student?s estimated cost of attendance less the student?s estimated financial assistance for that period and in the case of a Direct Subsidized Loan, the borrower?s expected family contribution for that period. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure amounts disbursed to students were properly determined. While performing procedures related to financial aid disbursements made to sixty-one students (with disbursements sampled totaling $1,110,440), we found that for two disbursements sampled, the incorrect grade-level was utilized to calculate the students award limits resulting in Direct Subsidized Loans disbursed (total of $6,271 and $6,234 Direct Loans was disbursed) which exceeded the set limit by $1,942 and $953, for a total over award of $2,895. Additionally, while performing procedures over financial aid disbursements made to sixty-one students (with disbursements sampled totaling $1,110,440), specifically over cost of attendance, we identified eight students sampled where the cost of attendance per the student?s records was overstated which resulted in the following: ? For four students sampled, clerical errors within the students cost of attendance records were identified resulting in one student being over awarded $25 of Direct PLUS Loans (a total of $17,088 of Direct Loans was disbursed). Three students with clerical errors did not result in an over award status because the student awards were less than the amount of the original cost of attendance. ? For four students sampled, the student?s status was incorrectly defaulting to full-time when each should have been identified as `part-time? which resulted in two students having Direct Unsubsidized Loans being over awarded in the amounts of $3,200 and $452 ($9,401 of Direct Loans was disbursed for each of the two students) and one student having Direct Subsidized and Unsubsidized ($11,094 of Direct Loans was disbursed), being over awarded in the amount of $5,912 (note this sample also had the incorrect grade-level discussed above which additionally contributed to the over award). One student sampled with the incorrect student status did not result in an over award status because amounts of loans secured were less than the annual loan limits and part-time cost of attendance. Questioned Cost: $12,484 Cause and Effect: In discussing these conditions with University management, they stated that: 1) clerical errors occurred related to manual cost of attendance adjustments; 2) grade-level data with their student system incorrectly populating from the FAFSA on certain students who had missing grade levels; and 3) student status? incorrectly defaulting on summer students enrolled in a certificate program. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process related to eligibility and consider implementing management review controls when the cost of attendance is manually adjusted to have someone other than the preparer review the accuracy of the data entered. We also recommend the University consider whether configuring and generating additional routine exception reports could inform management of discrepancies that would detect errors which impact eligibility determinations.
The University created additional reporting to identify student grade level reported on student system (SGASTDN) to the calculated grade level (ROASTAT) and any blanks. In addition, to the report which was created prior to this citing, training directly from the software provider has been scheduled. The University will review the option of creating a specific budget or packaging group for students in certificate programs. This would afford rules to award only level one loan limits regardless of calculated grade level. Standard cost of attendance (coa) is posted by system processing rules. In certain situations, the coa may be adjusted manually by staff. The student information system does track and log these updates. The University will increase training regarding coa adjustments, strengthen standard posting of changes and why. A report has been created to identify any change to the standard budget component. This will be added as a point of review for the compliance coordinator. The primary risk area is summer since it is a manual process. The use of algorithmic budgeting will assist with changes to coa as well. In addition, the University is working with software provider to establish algorithmic budgeting rules. This option allows cost of attendance (coa) to be completed by enrollment period versus aid periods. The benefit is coa can be estimated at full-time and prior to disbursement adjust coa to part-time. The office of student financial services is working with the University to identify and address additional human resources needed to best address increased volume and greater compliance. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by July 1, 2023.
Finding 2022 008 Federal Program Title ? Student Financial Assistance Cluster ? Federal Pell Grant Program Assistance Listing No. ? 84.063 Federal Agency ? U.S. Department of Education Federal Award Number ?P063Q211755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Reporting Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Chapter 2 of the Federal Student Aid Handbook, an institution must submit Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure Pell Grant disbursement records are submitted to the COD no later than 15 days after making the disbursement. We noted two of sixty samples where the University submitted the Pell Grant disbursement records to the COD 34 and 80 days of disbursement which was not within the 15 day requirement. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in reporting disbursement record reports to the COD later than the 15 day requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure Pell Grant disbursement records are submitted to COD no later than 15 days after making the disbursement.
Show full finding ▾Hide full finding ▴Finding 2022 008 Federal Program Title ? Student Financial Assistance Cluster ? Federal Pell Grant Program Assistance Listing No. ? 84.063 Federal Agency ? U.S. Department of Education Federal Award Number ?P063Q211755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Reporting Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Chapter 2 of the Federal Student Aid Handbook, an institution must submit Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure Pell Grant disbursement records are submitted to the COD no later than 15 days after making the disbursement. We noted two of sixty samples where the University submitted the Pell Grant disbursement records to the COD 34 and 80 days of disbursement which was not within the 15 day requirement. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that capacity issues resulted in reporting disbursement record reports to the COD later than the 15 day requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure Pell Grant disbursement records are submitted to COD no later than 15 days after making the disbursement.
The University will implement a two-step review internally to ensure records are reviewed within the required days. The University is filling vacant positions and reviewing additional operations support. Additionally, most of the errors occurred when a student did not answer completely or correctly the high school graduation information on the Free Application for Federal Student Aid (FAFSA), questions 26 and/or 27. The system is set to hold any loan disbursements if this question and associated C Flags are present. Pell disbursement, however, bypasses this control. The University has established a procedure to identify in the extract log errors from attempting to disburse. A hold will be placed on the student account, and if any Pell disbursement is not fully accepted, it will be reversed. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by August 1, 2023
Finding 2022 009 Federal Program Title ? Student Financial Assistance Cluster ? Federal Direct Student Loans Assistance Listing No. ? 84.268 Federal Agency ? U.S. Department of Education Federal Award Number ? P268K221755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Special Tests and Provisions - Disbursements To or On Behalf of Students Criteria: In accordance with 34 CFR 668.165, if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent, no earlier than 30 days before the disbursement and no later than 30 days after the disbursement, in writing of the anticipated date and amount of the loan disbursement, the student?s right or parent?s right to cancel all or a portion of the loan or loan disbursement and have the loan proceeds returned to the holder of that loan, and the procedures and time in which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to the special tests and provisions ? disbursements to or on behalf of students, we selected sixty-one students and identified twenty-two exceptions as follows: ? For nine of the sixty-one students selected for testwork, the University did not send the required notification to the student or parent for ten disbursements. ? For thirteen of the sixty-one students selected for testwork, the University did not maintain sufficient supporting documentation to evidence the University sent the required notification to the student or parent within 30 days after the disbursement for thirteen disbursements. The University did not have an effective system of internal control in place to notify the student, or parent, in writing of the date and amount of Direct Loan disbursement, the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan. Additionally, the University did not have an effective system of internal control in place to ensure adequate records were maintained to evidence that Direct Loan disbursement notifications were sent to student?s or parents. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that employee turnover and the re-distribution of responsibilities to balance workloads for six months of the fiscal year resulted in noncompliance with the Special Tests and Provisions - Disbursements To or On Behalf of Students compliance requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen processes and internal controls to ensure the University complies with the Special Tests and Provisions - Disbursements To or On Behalf of Students compliance requirement, including sending the required notification to the student or parent within 30 days after disbursement and maintaining adequate supporting documentation. Additionally, we recommend the University consider whether configuration of additional exception reports would help prevent or detect noncompliance.
Show full finding ▾Hide full finding ▴Finding 2022 009 Federal Program Title ? Student Financial Assistance Cluster ? Federal Direct Student Loans Assistance Listing No. ? 84.268 Federal Agency ? U.S. Department of Education Federal Award Number ? P268K221755 Grant Award Period ? July 1, 2021 to June 30, 2022 Compliance Requirement ? Special Tests and Provisions - Disbursements To or On Behalf of Students Criteria: In accordance with 34 CFR 668.165, if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent, no earlier than 30 days before the disbursement and no later than 30 days after the disbursement, in writing of the anticipated date and amount of the loan disbursement, the student?s right or parent?s right to cancel all or a portion of the loan or loan disbursement and have the loan proceeds returned to the holder of that loan, and the procedures and time in which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to the special tests and provisions ? disbursements to or on behalf of students, we selected sixty-one students and identified twenty-two exceptions as follows: ? For nine of the sixty-one students selected for testwork, the University did not send the required notification to the student or parent for ten disbursements. ? For thirteen of the sixty-one students selected for testwork, the University did not maintain sufficient supporting documentation to evidence the University sent the required notification to the student or parent within 30 days after the disbursement for thirteen disbursements. The University did not have an effective system of internal control in place to notify the student, or parent, in writing of the date and amount of Direct Loan disbursement, the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan. Additionally, the University did not have an effective system of internal control in place to ensure adequate records were maintained to evidence that Direct Loan disbursement notifications were sent to student?s or parents. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that employee turnover and the re-distribution of responsibilities to balance workloads for six months of the fiscal year resulted in noncompliance with the Special Tests and Provisions - Disbursements To or On Behalf of Students compliance requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen processes and internal controls to ensure the University complies with the Special Tests and Provisions - Disbursements To or On Behalf of Students compliance requirement, including sending the required notification to the student or parent within 30 days after disbursement and maintaining adequate supporting documentation. Additionally, we recommend the University consider whether configuration of additional exception reports would help prevent or detect noncompliance.
The University will continue to work with our Information Technology to update the process. Matching with the current process for parent loan notification is the initial step. That process does include but does not fully rely on a trigger in the student system communication forms. (no parent loan citing). In an overall process improvement, the goal is to move out of the webfocus engagement to a new automated process. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by July 1, 2023
Finding 2022-010 Federal Program Title ? Student Financial Assistance Cluster ? Federal Perkins Loan Program Assistance Listing No. ? 84.038 Federal Agency ? U.S. Department of Education Federal Award Number ? Not applicable Grant Award Period ? Not applicable Compliance Requirement ? Special Tests and Provisions ? Perkins Loan Recordkeeping and Record Retention Criteria: According to 34 CFR 674.19(e), institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. Disbursement records, electronic authentication and signature records for loans made with an MPN, must also be retained by the institution. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicers most recent Title IV compliance audit. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure appropriate due diligence was documented regarding the third-party servicers most recent Title IV compliance. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that a lack of policies that require documentation of the review of the third-party servicer compliance report was the cause. The lack of appropriate due diligence could result in recordkeeping and record retention issues at the third-party being undetected by the University. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at its current processes and its internal controls to ensure appropriate due diligence is being performed and documented by a control operator that is knowledgeable of the Title IV requirements and the functions being performed by the third-party servicer on behalf of the University.
Show full finding ▾Hide full finding ▴Finding 2022-010 Federal Program Title ? Student Financial Assistance Cluster ? Federal Perkins Loan Program Assistance Listing No. ? 84.038 Federal Agency ? U.S. Department of Education Federal Award Number ? Not applicable Grant Award Period ? Not applicable Compliance Requirement ? Special Tests and Provisions ? Perkins Loan Recordkeeping and Record Retention Criteria: According to 34 CFR 674.19(e), institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. Disbursement records, electronic authentication and signature records for loans made with an MPN, must also be retained by the institution. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicers most recent Title IV compliance audit. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure appropriate due diligence was documented regarding the third-party servicers most recent Title IV compliance. Questioned Cost: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that a lack of policies that require documentation of the review of the third-party servicer compliance report was the cause. The lack of appropriate due diligence could result in recordkeeping and record retention issues at the third-party being undetected by the University. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at its current processes and its internal controls to ensure appropriate due diligence is being performed and documented by a control operator that is knowledgeable of the Title IV requirements and the functions being performed by the third-party servicer on behalf of the University.
The Controller?s office will implement a process in which an individual will formally document their review of the third-party servicer?s most recent Title IV compliance audit in a memorandum. The memorandum will then be reviewed by another individual other than the preparer. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
Finding 2022 011 Federal Program Title ? COVID-19 - National Organizations of State and Local Officials Assistance Listing No. ? 93.011 Federal Agency ? U.S. Department of Health and Human Services Federal Award Numbers ? 1 U3SHS42192-01-00 and 1 G32HS42670-01-00 Grant Award Periods ? June 1, 2021 to August 31, 2022 and July 31, 2021 to October 31, 2022, respectively Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Additionally, the HHS Grants Policy for educational institutions requires a plan confirmation system (system) for professorial and other professional staff members that is based on budgeted, planned, or assigned work activity and that is updated to reflect any significant changes in work distribution. The system must be incorporated into the organization?s official records and must identify activity applicable to each sponsored agreement and to each category needed to identify indirect costs and the functions to which they are allocable. At least annually, the employee, principal investigator, or responsible official will verify, by suitable means, that the work was performed and that the salaries and wages charged to sponsored agreements, whether as direct charges or in other categories of cost, are reasonable in relation to the work performed. A system, supported by after-the-fact activity reports, that reflects the distribution of covered employees? activity allocable to each grant and includes identification and recording of significant changes in work activity when initial charges were based on estimates. For professorial and other professional staff members, the activity reports will be prepared each academic term, but at least every 6 months. The University did not follow their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not adhere to the HHS Grants Policy which requires after-the-fact activity reports. Additionally, the University did not adhere to their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted two of our fourteen sampled effort verification reports that were noncompliant. One effort verification report was not certified as the employee resigned and an effort verification report was not initiated as part of their exit procedures. Additionally, the employee?s supervisor also resigned. Lastly, one effort verification report was not certified within the 30-calendar day policy. Total payroll and fringe totaled approximately $320,000 during fiscal year 2022. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles specific to effort reporting. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated that there was a missing management review control to prevent noncompliance specific to the timeliness of the certifications of effort reports contributed to the noncompliance with the activities allowed/unallowed and allowable costs/cost principles specific to effort reporting. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that certification of effort reports complies with both federal requirements and University policy. Additionally, we recommend the University take a fresh look at policies and procedures in place when an employee resigns to consider whether exit procedures should include the initiation and certification of an effort verification report prior to departure.
Show full finding ▾Hide full finding ▴Finding 2022 011 Federal Program Title ? COVID-19 - National Organizations of State and Local Officials Assistance Listing No. ? 93.011 Federal Agency ? U.S. Department of Health and Human Services Federal Award Numbers ? 1 U3SHS42192-01-00 and 1 G32HS42670-01-00 Grant Award Periods ? June 1, 2021 to August 31, 2022 and July 31, 2021 to October 31, 2022, respectively Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Additionally, the HHS Grants Policy for educational institutions requires a plan confirmation system (system) for professorial and other professional staff members that is based on budgeted, planned, or assigned work activity and that is updated to reflect any significant changes in work distribution. The system must be incorporated into the organization?s official records and must identify activity applicable to each sponsored agreement and to each category needed to identify indirect costs and the functions to which they are allocable. At least annually, the employee, principal investigator, or responsible official will verify, by suitable means, that the work was performed and that the salaries and wages charged to sponsored agreements, whether as direct charges or in other categories of cost, are reasonable in relation to the work performed. A system, supported by after-the-fact activity reports, that reflects the distribution of covered employees? activity allocable to each grant and includes identification and recording of significant changes in work activity when initial charges were based on estimates. For professorial and other professional staff members, the activity reports will be prepared each academic term, but at least every 6 months. The University did not follow their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not adhere to the HHS Grants Policy which requires after-the-fact activity reports. Additionally, the University did not adhere to their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted two of our fourteen sampled effort verification reports that were noncompliant. One effort verification report was not certified as the employee resigned and an effort verification report was not initiated as part of their exit procedures. Additionally, the employee?s supervisor also resigned. Lastly, one effort verification report was not certified within the 30-calendar day policy. Total payroll and fringe totaled approximately $320,000 during fiscal year 2022. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles specific to effort reporting. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated that there was a missing management review control to prevent noncompliance specific to the timeliness of the certifications of effort reports contributed to the noncompliance with the activities allowed/unallowed and allowable costs/cost principles specific to effort reporting. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that certification of effort reports complies with both federal requirements and University policy. Additionally, we recommend the University take a fresh look at policies and procedures in place when an employee resigns to consider whether exit procedures should include the initiation and certification of an effort verification report prior to departure.
The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.
Finding 2022 012 Federal Program Title ? COVID-19 - National Organizations of State and Local Officials Assistance Listing No. ? 93.011 Federal Agency ? U.S. Department of Health and Human Services Federal Award Number ? 1 U3SHS42192-01-00 Grant Award Period ? June 1, 2021 to August 31, 2022 Compliance Requirement ? Reporting Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109 282), as amended by Section 6202 of Public Law 110 252, referred as the ?Transparency Act? that are codified in 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report first tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure that all required reports were submitted. While performing testwork over FFATA reporting for four of seven subrecipients, it was identified that FFATA reporting was not completed during fiscal year 2022 for two of the eight first tier subawards of $30,000 or more. See Schedule of Findings and Questioned Costs for chart/table Questioned Costs: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that a lack of a management review control that operated effectively over FFATA reporting for subawards greater than $30,000 contributed to the noncompliance with the Reporting compliance requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University submit the 2 additional required FFATA reports. Additionally, we recommend the University strengthen its processes and internal controls to ensure the University has both preventive and detective internal controls in place to ensure that reports for first tier subawards of $30,000 or more are reported to the FSRS as required.
Show full finding ▾Hide full finding ▴Finding 2022 012 Federal Program Title ? COVID-19 - National Organizations of State and Local Officials Assistance Listing No. ? 93.011 Federal Agency ? U.S. Department of Health and Human Services Federal Award Number ? 1 U3SHS42192-01-00 Grant Award Period ? June 1, 2021 to August 31, 2022 Compliance Requirement ? Reporting Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109 282), as amended by Section 6202 of Public Law 110 252, referred as the ?Transparency Act? that are codified in 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report first tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure that all required reports were submitted. While performing testwork over FFATA reporting for four of seven subrecipients, it was identified that FFATA reporting was not completed during fiscal year 2022 for two of the eight first tier subawards of $30,000 or more. See Schedule of Findings and Questioned Costs for chart/table Questioned Costs: There are no questioned costs. Cause and Effect: In discussing these conditions with University management, they stated that a lack of a management review control that operated effectively over FFATA reporting for subawards greater than $30,000 contributed to the noncompliance with the Reporting compliance requirement. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University submit the 2 additional required FFATA reports. Additionally, we recommend the University strengthen its processes and internal controls to ensure the University has both preventive and detective internal controls in place to ensure that reports for first tier subawards of $30,000 or more are reported to the FSRS as required.
During fiscal year 2022, the University recognized that its FFATA process did not have adequate internal controls in place and reorganized its operations to provide strong controls and management review. As of July 1, 2022, FFATA reporting was moved into the team responsible for issuing subawards and new processes were implemented to ensure that FFATA reports processed with the outbound subawards. Examples of these new processes include, but are not limited to: (1) designating one team to process subawards in accordance with a uniform set of guidelines to ensure that the elements required for FFATA reporting in fsrs.gov are including in the subaward document(s) and to ensure that the responsible party for submitting FFATA reports is always aware of all outgoing subaward actions that may need to be reported and (2) the development and management of a subaward tracker identifying each subaward action issued by the University that includes, among other data elements, the FFATA status of each of those subaward actions (e.g. is the prime award subject to FFATA, has the reporting threshold been met for that subaward or subaward action, date of full execution of the subaward action, due date for submitting the report in fsrs.gov, and the date the report was submitted in fsrs.gov). Management will further review this process alongside the finding and ensure that current policies and procedures reflect best practices. The University will also process the 2 additional FFATA reports for One Heart Many Hands as soon as the organization?s registration is approved and their Unique Entity Identified (UEI) has been issued by the System for Award Management (SAM). Alexis Bruce-Staudt, Assistant Vice President for Research Administration and Operations, is responsible for the above remediation items being addressed by June 30, 2023.
FAC accepted this audit on September 27, 2022 — management decision was due March 27, 2023.
Finding 2021-001 Federal Program Title ? Research and Development Cluster (R&D) Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Periods ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Additionally, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Further, as set forth in 2 CFR 200, the University is required to ensure allowable costs do not consist of improper payments, including payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments). Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing procedures related to personnel expenses, we noted the University had not followed their `Effort Reporting Policy? which states ?On a regular basis (every six months) an effort report form will be generated from the University?s effort reporting system for faculty, managerial and professional, clerical and technical staff, and post-doctoral associates whose compensation was charged in whole or in part to a sponsored project during the respective effort period. Specifically, the University did not send effort reports `every six months? and instead, sent all effort reports on September 7, 2021 that included all fiscal year 21 salaries and wages. Additionally, the University did not follow their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted three of our sixty sampled effort reports that had not been returned within the 30 calendar day policy. While performing procedures related to cost transfers, we noted the University had not followed their `Cost Transfer Policy? which states ?Cost transfers for current transactions must occur on a timely basis?. The University?s cost transfer policy defines timely as ?occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)?. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted forty-seven of our sixty-nine sampled cost transfers where the cost transfer date was between 91 and 730 days past the date the original expenditure was incurred (12 were between 91 and 180 days past, 19 were between 181 and 270 days past, and 16 were greater than 271 days past). Additionally, for $372,483 of costs transfers sampled, the University did not have detailed or summary documentation that fully explained how each error occurred. Additionally, we noted the following exceptions related to cost transfers: Transactions where labor charges were recorded via a cost transfer without an effort report that supported the cost transfer before the cost transfer was recorded: See Schedule of Findings and Questioned Costs for chart/table A transaction recorded as a cost transfer that moved FY21 expenditures off a federal grant after compliance testwork had started and also removed labor charges without an effort report that supported the costs transfer: See Schedule of Findings and Questioned Costs for chart/table A transaction recorded as a cost transfer dated June 30, 2022 to record F&A costs to a federal award that had a period of performance that ended June 30, 2020: See Schedule of Findings and Questioned Costs for chart/table Additionally, while performing audit procedures related to activities allowed and unallowed and allowable costs/cost principles, we noted one of sixty subrecipient invoices selected for testwork in the amount of $690 (Department of Health and Human Services, ALN 93.279, Award number R01DA043543) that was not approved per the electronic approval flow parameters programmed within Workday. Additionally, this subrecipient invoice was erroneously paid twice and indirect costs in the amount of $355 were charged to the grant twice resulting in a total of $1,045 of unallowable costs. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles. Questioned Cost: Questioned costs are not determinable. Cause and Effect: The University implemented several modules of Workday as of July 1, 2020, including the grants module. Within the Workday grants module, federal R&D Cluster activities are accounted for at the `grant level? which allows the University to track the specific budget provided by the individual agreement, period of availability, approved overhead rate, etc. `Grant level? activity then rolls up to the `award level?. The migration of data for federal R&D awards from the previous system (Banner) to the Workday grants module resulted in implementation issues that required significant additional laborious manual processes which were outside the University?s normal process for managing federal R&D awards, including tracking via ad hoc spreadsheets maintained outside Workday. This resulted in Workday not containing complete accounting for all aspects of R&D activity at the `grant level?. Workday implementation issues resulted in the following: 1) effort reports were not available to be sent every six months according to the University?s policy; 2) increased volume and delayed timing of preparing and posting cost transfers; 3) significant delays in the preparation of invoices/billings to federal awarding agencies for federal R&D Cluster activity for awards that operated on a cash reimbursement basis as all invoicing had to be done manually which resulted in the University being more than a year behind in billings; and 4) manual tracking and preparation of closeout reports. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that all R&D Cluster expenditures are properly reviewed for compliance with activities allowed or unallowed and adherence to allowable cost principles/cost principles and the Universities established policies. Additionally, we recommend the University enhance its internal control process to ensure the University is performing cost transfers and cash drawdowns on a timely basis, has adequate supporting documentation, and takes necessary action to significantly reduce the volume of cost transfers. Lastly, we recommend the University determine what additional Workday reporting is needed to monitor compliance effectively and efficiently for activities allowed or unallowed and allowable costs/cost principles. View of Responsible Official: The University concurs with this finding, noting that it was largely a product of a new system implementation. These findings are new and do not represent repeat findings. Many of the issues noted above have since been corrected during FY 2022. As noted, the University?s policies and procedures reflect our normal way of operating. The University will implement stronger controls and update policies to ensure that they are well aligned with the new financial system. The University implemented Workday July 1, 2020 and the period under audit was the first year of the University?s use of this new financial system. Implementation of the Workday Grants Module resulted in an effort certification system that did not run correctly during the first certification period of the year so instead of every 6 months, an annual certification was completed. Due to implementation of Workday, the University allowed cost transfers in higher volumes and later than it had in the prior year. While we are confident that we have resolved the underlying issues related to cost transfers at this time, we note that this was not fully resolved in FY 2021 and may impact a subsequent audit period. The University utilized manual invoicing throughout the period to ensure that amounts invoiced followed Uniform Guidance and were correctly charged. By the end of FY 2022, the University had returned to regular invoicing and entirely system-generated invoices. Because this fiscal year was the first use of Workday effort certifications, the University did not anticipate that effort reports would not run in cases where effort was allocated to an award after the end of the fiscal year. The University is now requiring a manual effort certification to be included with labor reallocations from the prior fiscal year. The errors in the effort certification have been resolved and the University has returned to following its policies on timely effort certification. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Show full finding ▾Hide full finding ▴Finding 2021-001 Federal Program Title ? Research and Development Cluster (R&D) Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Periods ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430 includes the standards for documentation of personnel expenses. According to 2 CFR 200.430(i)(1), charges to federal awards for salary and wages must be based on records that accurately reflect the work performed. Among other requirements within 2 CFR 200.430(i)(1), section (i) states records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and section (v) states that the records must comply with established accounting policies and practices. Additionally, the National Institutes of Health (NIH) Grants Policy Statement section 7.5, Cost Transfers, Overruns, Accelerated and Delayed Expenditures, states that cost transfers to NIH grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official. Documentation must be maintained of cost transfers, pursuant to 2 CFR Part 200.337 and 45 CFR Part 75.364. The recipient should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, recipients are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. Further, as set forth in 2 CFR 200, the University is required to ensure allowable costs do not consist of improper payments, including payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments). Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing procedures related to personnel expenses, we noted the University had not followed their `Effort Reporting Policy? which states ?On a regular basis (every six months) an effort report form will be generated from the University?s effort reporting system for faculty, managerial and professional, clerical and technical staff, and post-doctoral associates whose compensation was charged in whole or in part to a sponsored project during the respective effort period. Specifically, the University did not send effort reports `every six months? and instead, sent all effort reports on September 7, 2021 that included all fiscal year 21 salaries and wages. Additionally, the University did not follow their `Effort Reporting Policy? which states ?Subjects must return the certified effort verification report no later than 30 calendar days after they have been distributed.? We noted three of our sixty sampled effort reports that had not been returned within the 30 calendar day policy. While performing procedures related to cost transfers, we noted the University had not followed their `Cost Transfer Policy? which states ?Cost transfers for current transactions must occur on a timely basis?. The University?s cost transfer policy defines timely as ?occurring no later than two accounting periods after the month end of the date of the original transaction (no later than 90 days total)?. The University did not have an effective system of internal control in place to timely discover errors and get them corrected as we noted forty-seven of our sixty-nine sampled cost transfers where the cost transfer date was between 91 and 730 days past the date the original expenditure was incurred (12 were between 91 and 180 days past, 19 were between 181 and 270 days past, and 16 were greater than 271 days past). Additionally, for $372,483 of costs transfers sampled, the University did not have detailed or summary documentation that fully explained how each error occurred. Additionally, we noted the following exceptions related to cost transfers: Transactions where labor charges were recorded via a cost transfer without an effort report that supported the cost transfer before the cost transfer was recorded: See Schedule of Findings and Questioned Costs for chart/table A transaction recorded as a cost transfer that moved FY21 expenditures off a federal grant after compliance testwork had started and also removed labor charges without an effort report that supported the costs transfer: See Schedule of Findings and Questioned Costs for chart/table A transaction recorded as a cost transfer dated June 30, 2022 to record F&A costs to a federal award that had a period of performance that ended June 30, 2020: See Schedule of Findings and Questioned Costs for chart/table Additionally, while performing audit procedures related to activities allowed and unallowed and allowable costs/cost principles, we noted one of sixty subrecipient invoices selected for testwork in the amount of $690 (Department of Health and Human Services, ALN 93.279, Award number R01DA043543) that was not approved per the electronic approval flow parameters programmed within Workday. Additionally, this subrecipient invoice was erroneously paid twice and indirect costs in the amount of $355 were charged to the grant twice resulting in a total of $1,045 of unallowable costs. The University did not have an effective system of internal control in place to ensure compliance with activities allowed/unallowed and allowable costs/cost principles. Questioned Cost: Questioned costs are not determinable. Cause and Effect: The University implemented several modules of Workday as of July 1, 2020, including the grants module. Within the Workday grants module, federal R&D Cluster activities are accounted for at the `grant level? which allows the University to track the specific budget provided by the individual agreement, period of availability, approved overhead rate, etc. `Grant level? activity then rolls up to the `award level?. The migration of data for federal R&D awards from the previous system (Banner) to the Workday grants module resulted in implementation issues that required significant additional laborious manual processes which were outside the University?s normal process for managing federal R&D awards, including tracking via ad hoc spreadsheets maintained outside Workday. This resulted in Workday not containing complete accounting for all aspects of R&D activity at the `grant level?. Workday implementation issues resulted in the following: 1) effort reports were not available to be sent every six months according to the University?s policy; 2) increased volume and delayed timing of preparing and posting cost transfers; 3) significant delays in the preparation of invoices/billings to federal awarding agencies for federal R&D Cluster activity for awards that operated on a cash reimbursement basis as all invoicing had to be done manually which resulted in the University being more than a year behind in billings; and 4) manual tracking and preparation of closeout reports. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that all R&D Cluster expenditures are properly reviewed for compliance with activities allowed or unallowed and adherence to allowable cost principles/cost principles and the Universities established policies. Additionally, we recommend the University enhance its internal control process to ensure the University is performing cost transfers and cash drawdowns on a timely basis, has adequate supporting documentation, and takes necessary action to significantly reduce the volume of cost transfers. Lastly, we recommend the University determine what additional Workday reporting is needed to monitor compliance effectively and efficiently for activities allowed or unallowed and allowable costs/cost principles. View of Responsible Official: The University concurs with this finding, noting that it was largely a product of a new system implementation. These findings are new and do not represent repeat findings. Many of the issues noted above have since been corrected during FY 2022. As noted, the University?s policies and procedures reflect our normal way of operating. The University will implement stronger controls and update policies to ensure that they are well aligned with the new financial system. The University implemented Workday July 1, 2020 and the period under audit was the first year of the University?s use of this new financial system. Implementation of the Workday Grants Module resulted in an effort certification system that did not run correctly during the first certification period of the year so instead of every 6 months, an annual certification was completed. Due to implementation of Workday, the University allowed cost transfers in higher volumes and later than it had in the prior year. While we are confident that we have resolved the underlying issues related to cost transfers at this time, we note that this was not fully resolved in FY 2021 and may impact a subsequent audit period. The University utilized manual invoicing throughout the period to ensure that amounts invoiced followed Uniform Guidance and were correctly charged. By the end of FY 2022, the University had returned to regular invoicing and entirely system-generated invoices. Because this fiscal year was the first use of Workday effort certifications, the University did not anticipate that effort reports would not run in cases where effort was allocated to an award after the end of the fiscal year. The University is now requiring a manual effort certification to be included with labor reallocations from the prior fiscal year. The errors in the effort certification have been resolved and the University has returned to following its policies on timely effort certification. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Finding 2021-001 - Activities Allowed or Unallowed and Allowable Costs/Cost Principles The University suspended enforcement of its cost transfer policies to address a large volume of transfers related to the Workday implementation. To correct this, effective July 1, 2022 the University returned to enforcing its policies around labor reallocation and cost transfers. Business managers and post award specialists were retrained on July 20, 2022 and August 31, 2022 and the University is monitoring monthly cost transfers going forward, with particular attention to those departments and business managers that generate larger volumes of transfers. The University is working with an external vendor to improve reporting with specific attention to cash management and cost transfers. To strengthen compliance overall, the University moved its grant accounting group into the office of the Chief Financial Officer on September 1, 2022.
Finding 2021-002 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS-2). An accurate DS-2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS-2. Amendments to the DS-2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS-2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University?s last submitted DS-2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS-2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University?s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS-2. Questioned Cost: There are no questioned costs. Cause and Effect: As a result of the University not having an effective system of internal control to ensure compliance with the requirements for the DS-2, a revised DS-2 was not prepared and submitted. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS-2 are met. Specifically, we recommend the University perform a thorough review of their existing DS-2 and determine what adjustments are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS-2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS-2 prior to any amendments being submitted. View of Responsible Official: The University concurs with the finding that the DS-2 needs to be updated to reflect changes made in the Workday implementation. The University began the process of updating the DS-2 as soon as this was recognized as a deficiency. The update will be led by the Office of the Vice President for Research and approved by the Office of the Vice President and Chief Financial Officer. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Show full finding ▾Hide full finding ▴Finding 2021-002 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.419, a higher education entity that receives an aggregate total of $50 million or more in Federal awards must disclose their cost accounting practices by filing a Disclosure Statement (DS-2). An accurate DS-2 must be maintained and the higher education entity must comply with the cost accounting practices established within the DS-2. Amendments to the DS-2 must be filed with the cognizant agency for indirect costs in advance of a disclosed practice being changed to comply with a new or modified standard, or when a practice is changed for other reasons. Amendments of a DS-2 may be submitted at any time. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University?s last submitted DS-2 to the U.S. Department of Health & Human Services was March 27, 2007. The University implemented significant portions of Workday on July 1, 2020. We noted multiple items in the existing DS-2 that are no longer applicable/accurate and/or refers to previous practices and policies, including those related to the University?s salary and wage accumulation system. The University did not have an effective system of internal control in place to ensure compliance with the requirements for amending its DS-2. Questioned Cost: There are no questioned costs. Cause and Effect: As a result of the University not having an effective system of internal control to ensure compliance with the requirements for the DS-2, a revised DS-2 was not prepared and submitted. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure requirements around the DS-2 are met. Specifically, we recommend the University perform a thorough review of their existing DS-2 and determine what adjustments are needed to reflect current policies and practices. Additionally, we recommend the University implement a process to routinely review the DS-2 so that any updates are submitted as required. Lastly, we recommend someone other than the preparer perform a review of the DS-2 prior to any amendments being submitted. View of Responsible Official: The University concurs with the finding that the DS-2 needs to be updated to reflect changes made in the Workday implementation. The University began the process of updating the DS-2 as soon as this was recognized as a deficiency. The update will be led by the Office of the Vice President for Research and approved by the Office of the Vice President and Chief Financial Officer. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Finding 2021-002 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles To correct this, the University began preparing an updated DS-2 and plans to submit it before the end of the calendar year. This will be reviewed both by the Chief Financial Officer and the Office of the Vice President for Compliance and Ethics prior to submission.
Finding 2021-003 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Equipment/Real Property Management Criteria: As set forth in 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, as set forth in 2 CFR 200.313(d)(2), a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: Responsibility for the physical inventory of property is pushed down to the University departments. Equipment verification forms are sent to each University department which request various information be completed once the physical inventory is performed to communicate the results of the physical inventory and determine whether the property records of the University need updated (i.e, the location, condition, etc). While performing audit procedures related to equipment/real property management, the following conditions were identified: ? Four of the nine equipment verification forms selected for testwork were not completed timely for fiscal year 2021 (the equipment verification forms were completed in February 2022, subsequent to our sample selections). One of the nine equipment verification forms subsequently completed, included documentation that the equipment could not be located by the department. We noted no evidence of follow-up procedures and no changes had been made to University?s property records. Subsequently during our physical inspection procedures, we located the piece of equipment at a location other than what was listed in the property records maintained by the University (Asset ID BA-00001556 listed below). ? During our physical inspection procedures, we noted six of the sixty equipment items selected for testwork that were not located at the location stated within the property records maintained by the University during fiscal year 2021 as follows: See Schedule of Findings and Questioned Costs for chart/table ? One of the sixty equipment items selected for testwork was identified as being disposed of during fiscalyear 2021 and the property records maintained by the University did not reflect the disposal during fiscal year 2021 (current per-unit fair market value was less than $5,000) as follows: See Schedule of Findings and Questioned Costs for chart/table ? Two of the sixty equipment items selected for testwork had been disposed of between the date the department completed the equipment verification form and when we performed physical inspection procedures without the disposal denoted in the accounting records as follows: See Schedule of Findings and Questioned Costs for chart/table ? One of the sixty equipment items selected for testwork did not have accurate property records resulting in the serial number on the piece of equipment not agreeing to the property records maintained by the University during fiscal year 2021 as follows: See Schedule of Findings and Questioned Costs for chart/table The University did not have an effective system of internal control in place to ensure physical inventory of property and related results reconciled with the property records at least once every two years and that property records were complete and accurate. Questioned Cost: There are no questioned costs. Cause and Effect: As a result of not having an effective system of internal controls to ensure physical inventories were being completed and that the University was maintaining accurate property records, physical inventories were performed and/or reported subsequent to our equipment/real property sample selections for four of the nine departments selected for testwork. Additionally, ten of the sixty pieces of equipment selected for testwork during fiscal year 2021 did not have fully accurate property records. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen processes and internal controls to ensure requirements around equipment/real property management are met. We recommend the University take a fresh look at their capital equipment recordkeeping policy. Additionally, we recommend each University department be provided with a deadline for completion of the physical inventory and that follow-up procedures be completed as necessary on any equipment verification forms not received by departments. Lastly, we recommend timely updates be made to the property records. View of Responsible Official: The University concurs with the above findings. The University?s current procedures include providing departments with deadlines for completing the annual equipment verification along with deadlines for follow-up requests. We will strengthen our follow-up procedures by escalating violations of noncompliance to Deans and/or Vice Presidents. The University?s conversion to Workday Financials accounting system also contributed to delays in recordkeeping. We continue to improve our utilization of Workday Financials to ensure timely updates are made to the property records. Contact Name: David Heimburger, Vice President and Chief Financial Officer Contact Telephone Number: 314-977-3139
Show full finding ▾Hide full finding ▴Finding 2021-003 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Equipment/Real Property Management Criteria: As set forth in 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, as set forth in 2 CFR 200.313(d)(2), a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Lastly, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: Responsibility for the physical inventory of property is pushed down to the University departments. Equipment verification forms are sent to each University department which request various information be completed once the physical inventory is performed to communicate the results of the physical inventory and determine whether the property records of the University need updated (i.e, the location, condition, etc). While performing audit procedures related to equipment/real property management, the following conditions were identified: ? Four of the nine equipment verification forms selected for testwork were not completed timely for fiscal year 2021 (the equipment verification forms were completed in February 2022, subsequent to our sample selections). One of the nine equipment verification forms subsequently completed, included documentation that the equipment could not be located by the department. We noted no evidence of follow-up procedures and no changes had been made to University?s property records. Subsequently during our physical inspection procedures, we located the piece of equipment at a location other than what was listed in the property records maintained by the University (Asset ID BA-00001556 listed below). ? During our physical inspection procedures, we noted six of the sixty equipment items selected for testwork that were not located at the location stated within the property records maintained by the University during fiscal year 2021 as follows: See Schedule of Findings and Questioned Costs for chart/table ? One of the sixty equipment items selected for testwork was identified as being disposed of during fiscalyear 2021 and the property records maintained by the University did not reflect the disposal during fiscal year 2021 (current per-unit fair market value was less than $5,000) as follows: See Schedule of Findings and Questioned Costs for chart/table ? Two of the sixty equipment items selected for testwork had been disposed of between the date the department completed the equipment verification form and when we performed physical inspection procedures without the disposal denoted in the accounting records as follows: See Schedule of Findings and Questioned Costs for chart/table ? One of the sixty equipment items selected for testwork did not have accurate property records resulting in the serial number on the piece of equipment not agreeing to the property records maintained by the University during fiscal year 2021 as follows: See Schedule of Findings and Questioned Costs for chart/table The University did not have an effective system of internal control in place to ensure physical inventory of property and related results reconciled with the property records at least once every two years and that property records were complete and accurate. Questioned Cost: There are no questioned costs. Cause and Effect: As a result of not having an effective system of internal controls to ensure physical inventories were being completed and that the University was maintaining accurate property records, physical inventories were performed and/or reported subsequent to our equipment/real property sample selections for four of the nine departments selected for testwork. Additionally, ten of the sixty pieces of equipment selected for testwork during fiscal year 2021 did not have fully accurate property records. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen processes and internal controls to ensure requirements around equipment/real property management are met. We recommend the University take a fresh look at their capital equipment recordkeeping policy. Additionally, we recommend each University department be provided with a deadline for completion of the physical inventory and that follow-up procedures be completed as necessary on any equipment verification forms not received by departments. Lastly, we recommend timely updates be made to the property records. View of Responsible Official: The University concurs with the above findings. The University?s current procedures include providing departments with deadlines for completing the annual equipment verification along with deadlines for follow-up requests. We will strengthen our follow-up procedures by escalating violations of noncompliance to Deans and/or Vice Presidents. The University?s conversion to Workday Financials accounting system also contributed to delays in recordkeeping. We continue to improve our utilization of Workday Financials to ensure timely updates are made to the property records. Contact Name: David Heimburger, Vice President and Chief Financial Officer Contact Telephone Number: 314-977-3139
Finding 2021-003 ? Equipment/Real Property Management To correct this, the University is currently updating its capital equipment recordkeeping policy to clearly outline responsibilities and escalation procedures for noncompliance. This correction has not yet been completed but will be completed by December 31, 2022. We are also working with the University?s Workday IT team to improve our utilization of Workday Financials to ensure timely updates are made to the property records, including accounting for disposals and location identifiers.
Finding 2021-004 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Period of Availability Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure costs were not recorded to grants beyond the end date of the federal award?s period of performance. While performing procedures related to period of availability, we noted expenditures being recorded up to 505 days past the end of the period of performance. Additionally, while performing period of performance procedures specific to the population of awards with end period of performance dates during the University?s fiscal year ended June 30, 2021, we noted seven of sixty samples where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Lastly, while performing period of performance procedures specific to personnel expenses, other than payroll and cost transfers, we noted five of two hundred twenty-six samples where the expenditure incurred date was after the period of performance as follows: See Schedule of Findings and Questioned Costs for chart/table Upon further inspection of federal award number 5U01DK061718-18, we determined an additional $86,477 of personnel expenses ($71,414 of salaries and $15,063 of fringe benefits), $804 of other than payroll, and $51,641 of F&A expenditures for a total of $140,409 had been recorded past the period of availability of June 30, 2020 and there were no carryover options within the grant documents. Questioned Cost: Questioned costs are not determinable. Cause and Effect: The University did not have automated controls within Workday that prevented additional charges/posting of transactions past the end of the grants period of performance. This resulted in numerous expenditures/cost transfers occurring subsequent to the period of performance. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure costs charged to federal awards are within the period of availability. We also recommend the University consider implementing automated controls within Workday that prevent the recording/posting of transactions within a specified timeframe after the end of the grants period of performance. View of Responsible Official: The University concurs with this finding, noting that while internal controls did not prevent charges from accumulating in the financial system, a process of manual reconciliation prevented these charges from being sought for federal reimbursement. The implementation of a new financial system and issues with creating system-generated invoices throughout FY 2021 resulted in manual invoices to ensure that correct amounts and award periods were utilized. As these invoices were recorded in the Workday system, this control failing was identified. The University is working with vendors to implement a solution that will prevent costs from being charged to the award after the award end date. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Show full finding ▾Hide full finding ▴Finding 2021-004 Federal Program Title ? Research and Development Cluster Assistance Listing No. ? Various Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? Various Grant Award Period ? Various Compliance Requirement ? Period of Availability Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure costs were not recorded to grants beyond the end date of the federal award?s period of performance. While performing procedures related to period of availability, we noted expenditures being recorded up to 505 days past the end of the period of performance. Additionally, while performing period of performance procedures specific to the population of awards with end period of performance dates during the University?s fiscal year ended June 30, 2021, we noted seven of sixty samples where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Lastly, while performing period of performance procedures specific to personnel expenses, other than payroll and cost transfers, we noted five of two hundred twenty-six samples where the expenditure incurred date was after the period of performance as follows: See Schedule of Findings and Questioned Costs for chart/table Upon further inspection of federal award number 5U01DK061718-18, we determined an additional $86,477 of personnel expenses ($71,414 of salaries and $15,063 of fringe benefits), $804 of other than payroll, and $51,641 of F&A expenditures for a total of $140,409 had been recorded past the period of availability of June 30, 2020 and there were no carryover options within the grant documents. Questioned Cost: Questioned costs are not determinable. Cause and Effect: The University did not have automated controls within Workday that prevented additional charges/posting of transactions past the end of the grants period of performance. This resulted in numerous expenditures/cost transfers occurring subsequent to the period of performance. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure costs charged to federal awards are within the period of availability. We also recommend the University consider implementing automated controls within Workday that prevent the recording/posting of transactions within a specified timeframe after the end of the grants period of performance. View of Responsible Official: The University concurs with this finding, noting that while internal controls did not prevent charges from accumulating in the financial system, a process of manual reconciliation prevented these charges from being sought for federal reimbursement. The implementation of a new financial system and issues with creating system-generated invoices throughout FY 2021 resulted in manual invoices to ensure that correct amounts and award periods were utilized. As these invoices were recorded in the Workday system, this control failing was identified. The University is working with vendors to implement a solution that will prevent costs from being charged to the award after the award end date. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Finding 2021-004 ? Period of Availability To correct this, the University is in the process of implementing and is currently testing automated controls in Workday that will prevent posting of transactions on awards after the period of availability. The University will also implement an automated task sent to grants managers at least 30 days prior to award end, preparing them for award closeout. These system changes have not yet been completed but will be completed by December 31, 2022.
Finding 2021-005 Federal Program Title ? COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing No. ? 84.425F Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? September 29, 2020 through January 17, 2022 Compliance Requirement ? Reporting Criteria: As set forth through guidance posted by the U.S. Department of Education (DOE), on May 11, 2021 and updated on May 24, 2021 and September 30, 2021 at https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf, Higher Education Emergency Relief Fund (HEERF) grantees receiving America Rescue Plan (ARP) funds must continue to adhere to the quarterly reporting requirements originally implemented through the CARES Act for HEERF I funding. These reporting requirements include the following: ? Quarterly Institutional Public Reporting Form for (a)(1) Institutional Portion must be conspicuously posted on the institutions? website no later than 10 days after the calendar quarter (April 10, July 10, October 10, January 10). ? Institutions combine all their HEERF funding streams (ARP, HEERF II CRRSAA and HEERF I CARES Act) in reporting their expenditures for institutional funds. ? Each report is separate for the calendar quarter reporting period and not cumulative. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to reporting, the following conditions were identified for the one report required for the fiscal year 2021 institutional portion: ? The report was not posted to the University?s website by the required posting date (the report was posted on July 15, 2021). ? The total amount of the report was understated by $7,417,962 which should have been allocated to the following report cost categories: providing additional emergency financial aid grants to students, subsidizing food service to reduce density in eating facilities, to provide pre-packaged meals, or to add hours to food service operations to accommodate social distancing, campus safety and operations, replacing lost revenue from academic sources, replacing lost revenue from auxiliary services sources. The University did not have an effective system of internal control in place to ensure the Section 18004(a)(1) institutional portion for the quarterly public reports were being posted timely and accurately. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control to ensure the required reports posted to the University?s website were publicly posted within the required timeframe and that the information included within the required reports was complete and accurate. As a result, the one required Section 18004(a)(1) reports, was not publicly posted within the required timeframe and the public posting did not contain a complete and accurate total amount of expenditures within the required report posted to the University?s website. Repeat Finding: A similar finding was reported in prior year audit as finding number 2020-001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure the required reports are publicly posted within the required timeframe and that the information included within the required reports is accurate and complete as required by DOE. View of Responsible Official: The University concurs with this finding. At the time the July 2021 report was due, the University was still seeking clarification on how data needed to be reported and misunderstood which amounts needed to be included. Because the University had fully expended its HEERF institutional funds by July 1, 2021, the correct report, now posted on the website, serves as the final report. Any additional reporting for HEERF will implement the procedure SLU used to ensure reporting compliance on the student portion. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Show full finding ▾Hide full finding ▴Finding 2021-005 Federal Program Title ? COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing No. ? 84.425F Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? September 29, 2020 through January 17, 2022 Compliance Requirement ? Reporting Criteria: As set forth through guidance posted by the U.S. Department of Education (DOE), on May 11, 2021 and updated on May 24, 2021 and September 30, 2021 at https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf, Higher Education Emergency Relief Fund (HEERF) grantees receiving America Rescue Plan (ARP) funds must continue to adhere to the quarterly reporting requirements originally implemented through the CARES Act for HEERF I funding. These reporting requirements include the following: ? Quarterly Institutional Public Reporting Form for (a)(1) Institutional Portion must be conspicuously posted on the institutions? website no later than 10 days after the calendar quarter (April 10, July 10, October 10, January 10). ? Institutions combine all their HEERF funding streams (ARP, HEERF II CRRSAA and HEERF I CARES Act) in reporting their expenditures for institutional funds. ? Each report is separate for the calendar quarter reporting period and not cumulative. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing audit procedures related to reporting, the following conditions were identified for the one report required for the fiscal year 2021 institutional portion: ? The report was not posted to the University?s website by the required posting date (the report was posted on July 15, 2021). ? The total amount of the report was understated by $7,417,962 which should have been allocated to the following report cost categories: providing additional emergency financial aid grants to students, subsidizing food service to reduce density in eating facilities, to provide pre-packaged meals, or to add hours to food service operations to accommodate social distancing, campus safety and operations, replacing lost revenue from academic sources, replacing lost revenue from auxiliary services sources. The University did not have an effective system of internal control in place to ensure the Section 18004(a)(1) institutional portion for the quarterly public reports were being posted timely and accurately. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control to ensure the required reports posted to the University?s website were publicly posted within the required timeframe and that the information included within the required reports was complete and accurate. As a result, the one required Section 18004(a)(1) reports, was not publicly posted within the required timeframe and the public posting did not contain a complete and accurate total amount of expenditures within the required report posted to the University?s website. Repeat Finding: A similar finding was reported in prior year audit as finding number 2020-001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure the required reports are publicly posted within the required timeframe and that the information included within the required reports is accurate and complete as required by DOE. View of Responsible Official: The University concurs with this finding. At the time the July 2021 report was due, the University was still seeking clarification on how data needed to be reported and misunderstood which amounts needed to be included. Because the University had fully expended its HEERF institutional funds by July 1, 2021, the correct report, now posted on the website, serves as the final report. Any additional reporting for HEERF will implement the procedure SLU used to ensure reporting compliance on the student portion. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Finding 2021-005 ? Reporting The University corrected the report and filed its final report for the CARES/HEERF Institutional Portion in February 2022. For all future CARES/HEERF reporting, the University has instituted new controls, requiring signoff by the relevant Vice President prior to public posting.
2020-001
Finding 2021-006 Federal Program Title ? Research and Development Cluster, COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion, and COVID-19 ? Provider Relief Funds Assistance Listing No. ? 93.855, 84.425E, and 93.498 Federal Agency ? U.S. Department of Health and Human Services and U.S. Department of Education Federal Award Numbers ? As listed in below table Grant Award Period ? Various Compliance Requirement ? Other ? Inaccurate Reporting of Expenditures on the Schedule of Expenditures of Federal Awards (SEFA) Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended. At a minimum, the schedule must include (1) a list of individual Federal programs by Federal agency. For Federal programs included in a cluster of programs, list individual Federal programs within a cluster of programs; (2) for Federal awards received as a subrecipient the name of the pass-through entity and identifying number of assigned by the pass-through entity shall be included; (3) provide total Federal awards expended for each individual Federal program and the CFDA/ALN number or other identifying number when the CFDA/ALN information is not available; (4) include total amount provided to subrecipient from each Federal program; (5) include notes that describe the significant accounting policies used in preparing the schedule. In addition, 2 CFR 200,303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure expenditures and amounts passed through to subrecipients are properly reported on the SEFA. Conditions Found: Federal expenditures reported in the fiscal year 2021 SEFA provided by the University did not agree to the University?s financial records or to specific guidance about what is to be reported on the SEFA. Specifically, we noted that expenditures in the amount of $4,005,057 should not have been reflected within the SEFA, which were corrected by University management as follows: See Schedule of Findings and Questioned Costs for chart/table Additionally, subrecipient expenditures were understated by $5,599,289 within the Research and Development Cluster as follows: See Schedule of Findings and Questioned Costs for chart/table Also, assistance listing numbers reported in the SEFA did not agree to the awards received by the University. Specifically, we noted the following differences for fiscal year 2021, which were corrected by University management on the corrected SEFA: See Schedule of Findings and Questioned Costs for chart/table Additionally, the University inappropriately included grant number HE2021-0165 in the amount of $350,204 in the fiscal year 2021 SEFA when the University was deemed a contractor by the primary recipient of the federal award. This was corrected by University management. Internal controls were not designed to ensure the SEFA is prepared accurately and in accordance with the Uniform Guidance. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control in place to ensure the accuracy of the amounts and assistance listing numbers reported in the SEFA, partly caused by staff shortages combined with the implementation of Workday. As a result, the fiscal year 2021 SEFA originally provided by University management was inaccurate. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen its processes and internal controls around the preparation of the SEFA to ensure it is prepared accurately and completely in accordance with the Uniform Guidance. View of Responsible Official: The University concurs with this finding. Challenges related to the Workday system implementation resulted in data errors that had to be manually corrected. The University has moved grant accounting into the office of the Chief Financial Officer to strengthen its financial reporting. It will further strengthen review of the SEFA by requiring signoff by both finance and research. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Show full finding ▾Hide full finding ▴Finding 2021-006 Federal Program Title ? Research and Development Cluster, COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion, and COVID-19 ? Provider Relief Funds Assistance Listing No. ? 93.855, 84.425E, and 93.498 Federal Agency ? U.S. Department of Health and Human Services and U.S. Department of Education Federal Award Numbers ? As listed in below table Grant Award Period ? Various Compliance Requirement ? Other ? Inaccurate Reporting of Expenditures on the Schedule of Expenditures of Federal Awards (SEFA) Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended. At a minimum, the schedule must include (1) a list of individual Federal programs by Federal agency. For Federal programs included in a cluster of programs, list individual Federal programs within a cluster of programs; (2) for Federal awards received as a subrecipient the name of the pass-through entity and identifying number of assigned by the pass-through entity shall be included; (3) provide total Federal awards expended for each individual Federal program and the CFDA/ALN number or other identifying number when the CFDA/ALN information is not available; (4) include total amount provided to subrecipient from each Federal program; (5) include notes that describe the significant accounting policies used in preparing the schedule. In addition, 2 CFR 200,303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure expenditures and amounts passed through to subrecipients are properly reported on the SEFA. Conditions Found: Federal expenditures reported in the fiscal year 2021 SEFA provided by the University did not agree to the University?s financial records or to specific guidance about what is to be reported on the SEFA. Specifically, we noted that expenditures in the amount of $4,005,057 should not have been reflected within the SEFA, which were corrected by University management as follows: See Schedule of Findings and Questioned Costs for chart/table Additionally, subrecipient expenditures were understated by $5,599,289 within the Research and Development Cluster as follows: See Schedule of Findings and Questioned Costs for chart/table Also, assistance listing numbers reported in the SEFA did not agree to the awards received by the University. Specifically, we noted the following differences for fiscal year 2021, which were corrected by University management on the corrected SEFA: See Schedule of Findings and Questioned Costs for chart/table Additionally, the University inappropriately included grant number HE2021-0165 in the amount of $350,204 in the fiscal year 2021 SEFA when the University was deemed a contractor by the primary recipient of the federal award. This was corrected by University management. Internal controls were not designed to ensure the SEFA is prepared accurately and in accordance with the Uniform Guidance. Questioned Cost: There are no questioned costs. Cause and Effect: The University did not have an effective system of internal control in place to ensure the accuracy of the amounts and assistance listing numbers reported in the SEFA, partly caused by staff shortages combined with the implementation of Workday. As a result, the fiscal year 2021 SEFA originally provided by University management was inaccurate. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University strengthen its processes and internal controls around the preparation of the SEFA to ensure it is prepared accurately and completely in accordance with the Uniform Guidance. View of Responsible Official: The University concurs with this finding. Challenges related to the Workday system implementation resulted in data errors that had to be manually corrected. The University has moved grant accounting into the office of the Chief Financial Officer to strengthen its financial reporting. It will further strengthen review of the SEFA by requiring signoff by both finance and research. Contact Name: Matthew Christian, Associate Vice President for Research Contact Telephone Number: 314-977-2047
Finding 2021-006 ? Other ? Inaccurate Reporting of Expenditures on the Schedule of Expenditures of Federal Awards (SEFA) The University is changing the process of development of the SEFA. All university-wide financial reporting, including the SEFA, will occur within the Controller?s Office where Sponsored Award Accounting was moved on September 1, 2022. The Controller and the Associate VP for Research will review the SEFA together and provide signoff to ensure that it is prepared accurately.
FAC accepted this audit on June 10, 2021 — management decision was due December 10, 2021.
Finding 2020-001 Federal Program Title ? COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund ? Student Aid Portion CFDA No. ? 84.425E Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? April 9, 2020 through April 8, 2021 Compliance Requirement ? Reporting Criteria: As set forth through guidance posted by the U.S. Department of Education (DOE), on May 6, 2020 and updated on September 1, 2020 at https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2020-05-06/higher-education-emergency-relief-fund-reporting-emergency-financial-aid-grants-students-updated-sept-1-2020, the following information must appear in a format and location that is easily accessible to the public, 30 days after the date of the institution?s Certification and Agreement with DOE under 18004(a)(1) and updated every 45 days thereafter: 1) An acknowledgement that the institution signed and returned to the DOE the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students. 2) The total amount of funds that the institution will receive or has received from the DOE pursuant to the institution?s Certification and Agreement [for] Emergency Financial Aid Grants to Students. 3) The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter). 4) The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act. 5) The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. 6) The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. 7) Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure the Section 18004(a)(1) student aid portion for the quarterly public reports were being posted timely and accurately. While performing audit procedures related to reporting, the following conditions were identified for one of the two total reports related to fiscal year 2020: ? The report was not posted to the University's website by the required posting date. ? The total amount of emergency financial aid grants distributed to students was understated by $3,300. ? The total number of students who received an emergency financial aid grant was understated by four students. Questioned Cost: Questioned costs are not determinable. Context: The University is required to publicly post certain information on their website no later than 30 days after the date of the institution?s Certification and Agreement with DOE, and update that information every 45 days thereafter (by posting a new report) in relation to Section 18004(a)(1). The University did not post to the University?s website an update of certain information within 45 days after the initial public posting. In addition, the information included within the public posting did not contain an accurate total amount of emergency federal aid grants distributed to students or total number of students who received an emergency financial aid grant. Cause and Effect: The University did not have an effective system of internal control to ensure the required reports posted to the University?s website were publicly posted within the required timeframe and that the information included within the required reports was accurate. As a result, one of the total of two Section 18004(a)(1) reports, were not publicly posted within the required timeframe and the public posting did not contain an accurate total amount of emergency federal aid grants distributed to students or total number of students who received an emergency financial aid grant. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure that the University has effective internal controls in place to ensure the required reports are publicly posted within the required timeframe and that the information included within the required reports is accurate as required by DOE. View of Responsible Official: The University concurs the reporting requirements were late in being defined and confusing with guidance for public posting as well as use of the Federal Funding Accountability and Transparency Act of 2006 (FFATA), Pub.L. 109-282, as amended by the Digital Accountability and Transparency Act (DATA Act), Pub.L. 113-101 to fulfill requirements. An error did occur when a report summary updated after May 22, 2020 was not pulled to update, rather the same report added to the web a second time. This has been corrected and CARES/HEERF I funding marked as final. Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Finding 2020-001 Federal Program Title ? COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund ? Student Aid Portion CFDA No. ? 84.425E Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? April 9, 2020 through April 8, 2021 Compliance Requirement ? Reporting Criteria: As set forth through guidance posted by the U.S. Department of Education (DOE), on May 6, 2020 and updated on September 1, 2020 at https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2020-05-06/higher-education-emergency-relief-fund-reporting-emergency-financial-aid-grants-students-updated-sept-1-2020, the following information must appear in a format and location that is easily accessible to the public, 30 days after the date of the institution?s Certification and Agreement with DOE under 18004(a)(1) and updated every 45 days thereafter: 1) An acknowledgement that the institution signed and returned to the DOE the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students. 2) The total amount of funds that the institution will receive or has received from the DOE pursuant to the institution?s Certification and Agreement [for] Emergency Financial Aid Grants to Students. 3) The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter). 4) The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act. 5) The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. 6) The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. 7) Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure the Section 18004(a)(1) student aid portion for the quarterly public reports were being posted timely and accurately. While performing audit procedures related to reporting, the following conditions were identified for one of the two total reports related to fiscal year 2020: ? The report was not posted to the University's website by the required posting date. ? The total amount of emergency financial aid grants distributed to students was understated by $3,300. ? The total number of students who received an emergency financial aid grant was understated by four students. Questioned Cost: Questioned costs are not determinable. Context: The University is required to publicly post certain information on their website no later than 30 days after the date of the institution?s Certification and Agreement with DOE, and update that information every 45 days thereafter (by posting a new report) in relation to Section 18004(a)(1). The University did not post to the University?s website an update of certain information within 45 days after the initial public posting. In addition, the information included within the public posting did not contain an accurate total amount of emergency federal aid grants distributed to students or total number of students who received an emergency financial aid grant. Cause and Effect: The University did not have an effective system of internal control to ensure the required reports posted to the University?s website were publicly posted within the required timeframe and that the information included within the required reports was accurate. As a result, one of the total of two Section 18004(a)(1) reports, were not publicly posted within the required timeframe and the public posting did not contain an accurate total amount of emergency federal aid grants distributed to students or total number of students who received an emergency financial aid grant. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure that the University has effective internal controls in place to ensure the required reports are publicly posted within the required timeframe and that the information included within the required reports is accurate as required by DOE. View of Responsible Official: The University concurs the reporting requirements were late in being defined and confusing with guidance for public posting as well as use of the Federal Funding Accountability and Transparency Act of 2006 (FFATA), Pub.L. 109-282, as amended by the Digital Accountability and Transparency Act (DATA Act), Pub.L. 113-101 to fulfill requirements. An error did occur when a report summary updated after May 22, 2020 was not pulled to update, rather the same report added to the web a second time. This has been corrected and CARES/HEERF I funding marked as final. Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
Finding 2020-001 ? Internal Controls for HEERF Reporting The University did not have an effective system of internal control to ensure the required reports posted to the University?s website were publicly posted within the required timeframe and that the information included within the required reports was accurate. As a result, one of the total of two Section 18004(a)(1) reports, were not publicly posted within the required timeframe and the public posting did not contain an accurate total amount of emergency federal aid grants distributed to students or total number of students who received an emergency financial aid grant. The University has corrected this report and filed its final report for CARES/HEERF I funding. For any future HEERF reporting, SLU has already instituted new controls, including adding dates to a master calendar for public reporting requirements, weekly reporting internally and monthly reporting to the Vice President. Remediation on this finding is complete. Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
Finding 2020-002 Federal Program Title ? Student Financial Assistance Cluster ? Federal Pell Grant Program and Federal Direct Student Loans CFDA No. ? 84.063, 84.268 Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? July 1, 2019 through June 30, 2020 Compliance Requirement ? Special Tests and Provisions ? Enrollment Reporting Criteria: As set forth in 34 CFR Section 685.309(b)(2), participating schools in the Direct Loan Program are to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure students enrollment status, for those who withdrew from the University during the fiscal year, were properly reported to the National Student Loan Data System (NSLDS) within 60 days of the change. While performing testwork over enrollment reporting, for 4 out of 42 students selected that withdrew from the University during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. ? For 3 out of a total population of 10 students that had a backdated withdraw during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. ? For 1 out of 32 students selected that withdrew, the enrollment status was not reported to the NSLDS within 60 days of the change during fiscal year 2020. Questioned Cost: Questioned costs are not determinable. Context: For 4 out of 42 students selected for testwork that withdrew from the University during fiscal year 2020, the University did not properly report to the NSLDS the enrollment status of the student within 60 days. For 3 out of a total population of 10 students selected that had a backdated withdraw and for 1 out of 32 students selected that had a withdraw during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. The total population of students that withdrew during fiscal year 2020 was approximately 160 students. Cause and Effect: University management indicated the University did not have an effective system of internal control in place, as prescribed by 2 CFR 200.303, to ensure that the data being input into the NSLDS system was submitted within 60 days for students that withdrew during fiscal year 2020. As a result, 4 out of 42 students selected for testwork were not reported to the NSLDS within 60 days of the change. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that accurate enrollment status data is being submitted for students who withdraw, as set forth in 34 CFR Section 685.309(b)(2). View of Responsible Official: The University concurs enhancement to internal controls should be put in place. The errors took place during a staffing transition at which time staff did not have full access to immediately update in NSLDS. That access was updated shortly afterwards with processing to include direct manual update on any backdated withdrawals. The process for calculating and reviewing is now collaboration of two managerial staff persons. The backdated enrollment changes are primarily vetted through the Academic Records Review Committee (ARRC). This group is chaired by the Associate Provost and University Registrar. The compliance coordinator will join that group to be part of any discussions. Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
Show full finding ▾Hide full finding ▴Finding 2020-002 Federal Program Title ? Student Financial Assistance Cluster ? Federal Pell Grant Program and Federal Direct Student Loans CFDA No. ? 84.063, 84.268 Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Period ? July 1, 2019 through June 30, 2020 Compliance Requirement ? Special Tests and Provisions ? Enrollment Reporting Criteria: As set forth in 34 CFR Section 685.309(b)(2), participating schools in the Direct Loan Program are to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure students enrollment status, for those who withdrew from the University during the fiscal year, were properly reported to the National Student Loan Data System (NSLDS) within 60 days of the change. While performing testwork over enrollment reporting, for 4 out of 42 students selected that withdrew from the University during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. ? For 3 out of a total population of 10 students that had a backdated withdraw during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. ? For 1 out of 32 students selected that withdrew, the enrollment status was not reported to the NSLDS within 60 days of the change during fiscal year 2020. Questioned Cost: Questioned costs are not determinable. Context: For 4 out of 42 students selected for testwork that withdrew from the University during fiscal year 2020, the University did not properly report to the NSLDS the enrollment status of the student within 60 days. For 3 out of a total population of 10 students selected that had a backdated withdraw and for 1 out of 32 students selected that had a withdraw during fiscal year 2020, the enrollment status was not reported to the NSLDS within 60 days of the change. The total population of students that withdrew during fiscal year 2020 was approximately 160 students. Cause and Effect: University management indicated the University did not have an effective system of internal control in place, as prescribed by 2 CFR 200.303, to ensure that the data being input into the NSLDS system was submitted within 60 days for students that withdrew during fiscal year 2020. As a result, 4 out of 42 students selected for testwork were not reported to the NSLDS within 60 days of the change. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that accurate enrollment status data is being submitted for students who withdraw, as set forth in 34 CFR Section 685.309(b)(2). View of Responsible Official: The University concurs enhancement to internal controls should be put in place. The errors took place during a staffing transition at which time staff did not have full access to immediately update in NSLDS. That access was updated shortly afterwards with processing to include direct manual update on any backdated withdrawals. The process for calculating and reviewing is now collaboration of two managerial staff persons. The backdated enrollment changes are primarily vetted through the Academic Records Review Committee (ARRC). This group is chaired by the Associate Provost and University Registrar. The compliance coordinator will join that group to be part of any discussions. Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
Finding 2020-002 ? Internal Controls for Enrollment Reporting The University did not have an adequate internal control process to ensure that accurate enrollment status data is being submitted for students who withdraw, as set forth in 34 CFR Section 685.309(b)(2). As a result, 4 out of 42 students selected for testwork were not reported to the NSLDS within 60 days of the change. The University attributes this to a staffing change that left key personnel without access to make these updates. To correct this, the University provided access to directly update NLDS information to staff completing the R2T4 calculations. This allows for immediate update to any backdated withdrawals. It also implemented a review process which includes two managerial staff for additional assessment. The backdated enrollment changes are primarily vetted through the Academic Records Review Committee (ARRC). This group is chaired by the Associate Provost and University Registrar. Going forward, the compliance coordinator will join that group to be part of any discussions. As a further control, the University will increase the number of R2T4 students selected annually for internal review as an additional evaluation item. Remediation on this finding will be completed by 6/30/2021 Contact Name: Cari Wickliffe, Assistant Vice President Contact Telephone Number: 314-977-2353
FAC accepted this audit on April 2, 2020 — management decision was due October 2, 2020.
FAC accepted this audit on February 14, 2019 — management decision was due August 14, 2019.
FAC accepted this audit on March 18, 2018 — management decision was due September 18, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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