Harris-Stowe State UniversityHigher Education

Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006 Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements. Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.

Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.

Finding 2023-005 – Material Weakness: Equipment and Real Property Management – Compliance and Control Finding ALN 84.031 – Title III – Higher Education – Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: • Equipment must be used in the program for which it was acquired; • Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; • A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; • Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University does not have a process in place to ensure federally funded equipment is subjected to a physical inventory observation at least once every two years. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds prior to 2022 has not been completed within the last two years. Identification As A Repeat Finding: 2022-011 and 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory observation for all equipment purchased with grant funding. Views Of Responsible Officials: The University has implemented guidelines for categorizing equipment and supplies. Additionally, HSSU is presently exploring an Asset Management software solution to facilitate inventory tracking and intends to carry out biannual inventory audits.

Finding 2023-006 – Significant Deficiency: Special Test and Provisions – Enrollment Reporting – Compliance and Control Finding ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is required to report changes to a student’s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days. Condition: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting. Effect: The University’s was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring. Questioned Costs: None. Context: Based on a sample of 40 students tested, the enrollment status of 1 student was not reported within the 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The University filled the Registrar position which had been vacant for 6 months. In addition, the Registrar’s Office implemented a control that includes running a monthly enrollment status report allowing for changes to be reported within the 60 day window. The current Registrar has also done Registrar training with the American Association of Collegiate Registrars and Admissions Officers (AACRAO).

Finding 2022-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that payroll costs were not supported with adequate documentation. Internal controls designed for these federal programs did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grants. Effect: Instances of noncompliance were not detected by management. Questioned Costs: TRIO Cluster - $40,361 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. National Science Foundation - $24,744 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Title III - $34,906 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: TRIO Cluster - For a sample of 40 individual costs charged to the grant, 26 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. National Science Foundation - For a sample of 40 individual costs charged to the grant, 24 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Title III - TRIO Cluster - For a sample of 40 individual costs charged to the grant, 21 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2021-003, 2021-008, 2021-015, 2020-003, and 2020-007 Recommendation: We recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University is working with our third-party payroll provider to automate time and effort reporting. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Finding 2022-005 ? Material Weakness: Eligibility ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, compliance documents to support the student?s eligibility were not provided. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-005 and 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third party to conduct an external review to ensure the program's compliance.

Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the TRIO Cluster. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.

Finding 2022-007 ? Material Weakness: Allowable Costs & Activities and Period of Performance? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) section 314(c )(1-3) notes that HEERF Institutional Portion funds are to be used to defray expenses associated with coronavirus or to carry out student support activities that address needs related to coronavirus. 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $766,177 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 23 individual costs charged to the grant, 4 items tested, all payroll related, did not include adequate documentation. For the payroll items, the University did not provide documentation to support the time and effort of each student worker charged to the grant. For a sample of 23 individual costs charged to the grant, 7 items tested were utilized to cover costs related to building renovations and the associated project management. The documentation provided did not indicate that these costs were utilized to defray expenses associated with coronavirus. The control over compliance to ensure costs charged to the grant were allowable did not operate effectively. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2021-010 Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. In addition, we recommend that management adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Finding 2022-008 ? Material Weakness: Allowable Costs and Activities and Period of Performance ? Control Finding ALN 84.425J ? Higher Education Emergency Relief Fund (HEERF) HBCU Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is allowed to utilize HEERF funding to reimburse lost revenues associated with room and board and childcare services. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The University did not provide supporting documentation that a second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: None noted Context: During the testing performed, it was noted that HEERF funds were utilized to reimburse the University for lost revenues. There was no control identified to ensure costs charged to the grant were allowable and incurred within the period of performance. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-011 and 2020-009. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University will document lost revenue in comparison to the Board of Regents approved budget. The calculation will be prepared by the Assistant Comptroller, reviewed by the Comptroller as the second reviewer, and approved by the Chief Financial Officer, as the third and final review for charges being allocated to the grant.

Finding 2022-009 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not provide proof that the quarterly reports for the Institutional Portion were posted to its website by required date. In addition, the University did not provide supporting documentation that a second review to verify that the information on the quarterly Institutional Portion reports and the Annual Report was accurate and that the reports were filed timely. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2021-013 and 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored, required information is communicated and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.

Finding 2022-010 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425E ? Higher Education Emergency Relief Fund (HEERF) Students Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Student Aid funds. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. Condition: The University did not report any HEERF Student Aid costs for fiscal year 2022. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public sufficient information regarding the spending of HEERF Student Aid that would allow the public to understand the proper amount and nature of its use of HEERF Student Aid funds. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: Not applicable. Context: The University did not report any HEERF Student Aid costs for fiscal year 2022. The University was not aware of the requirements to report the student portion costs. Identification As A Repeat Finding: Some portions of this finding are a repeat of 2021-014 and 2020-011. Recommendation: We recommend that management implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.

Finding 2022-011 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: 2021-017 Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check, inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.

Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, we noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Finding 2022-013 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly under awarded Pell grants for 3 students in the amount of $300 and over awarded Federal Direct Loans for 2 students in the amount of $4,500. Identification As A Repeat Finding: 2021-019. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the 2nd review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.

Finding 2022-014 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $914 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 18 students, the University did not exclude a scheduled break of five consecutive days for 8 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2021-021 and 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ::

Finding 2021-003 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $70,894 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 40 individual costs charged to the grant, 24 items tested (1 nonpayroll and 23 payroll) did not include adequate documentation. For 1 nonpayroll related cost, the University did not provide support for the amount charged to the grant. For 23 payroll items, the University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: 2020-003 Recommendation: We recommend that management retain invoices and receipts for all nonpayroll items charged to the grant. Management should also adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University has re-instated the payroll for compliance with level of effort. All employees paid on a grant will now confirm monthly by signing a compliance form. The University is also implementing a technology solution in collaboration with our payroll partner ADP to automate this process using electronic forms and workflow. The Director of Title III and Compliance and the Comptroller will perform periodic reviews of these activities to ensure that policies are adhered to.

Finding 2021-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2020-004, 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University will implement controls to ensure proper documentation is maintained and reconciled prior to any reimbursement being drawdown from Federal sources. The documents will be reviewed and approved by a separate party from the person performing the cash drawdown to ensure the proper segregation of duties exist.

Finding 2021-005 ? Material Weakness: Eligibility ? Control Finding ALN 84.042 ? Student Support Services and 84.044 ? Talent Search ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, specifically related to Talent Search and Student Support Services, controls over compliance are not in place as it relates to determining participant eligibility. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2020-006 Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University has a policy that was not followed in a timely fashion due to staffing shortages. The Administration has met with the individual department and the appropriate individuals to ensure they understand the policy and what the expectations are regarding compliance. All employees will be accountable for compliance in this matter. The University has allocated sufficient resources to ensure the policy can be adhered to, and an external departmental review process has been put in place to ensure that this situation does not repeat itself.

Finding 2021-006 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.042 ? Student Support Services and 84.044 ? Talent Search ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Condition: The University was unable to provide a copy of the annual performance report for Student Support Services and Talent Search that was submitted to the Department of Education for the current project period. Without a copy of the submission, it is not possible to determine if accurate information was submitted to the Department of Education. Cause: Management only retained the signature pages for the submission and did not retain a full copy of the annual performance report that was submitted for Student Support Services and Talent Search. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: The University submitted the Annual Performance Report for Student Support Services and Talent Search but only retained the signature page of the submission. We were unable to determine if the key line items identified by Uniform Guidance were accurately submitted to the Department of Education. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management put a control in place to ensure a full copy of the annual performance report is retained after the submission. Views Of Responsible Officials: The University has a policy that was not followed in a timely fashion due to training needs. The Administration has met with the individual department and the appropriate individuals to ensure they understand the policy and what the expectations are regarding compliance. All employees will be accountable for compliance in this matter. The University has allocated sufficient resources to ensure the policy can be adhered to, and an external departmental review process has been put in place to ensure that this situation does not repeat itself.

Finding 2021-007 ? Material Weakness: Special Tests and Provisions ? Compliance and Control Finding ALN 84.042 ? Student Support Services and 84.044 ? Talent Search ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that the University provide certain required services under the program. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Documentation was not retained to determine if required program services were provided. A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, specifically related to Talent Search and Student Support Services, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: The University has a policy that was not followed in a timely fashion due to staffing shortages. The Administration has met with the individual department and the appropriate individuals to ensure they understand the policy and what the expectations are regarding compliance. All employees will be accountable for compliance in this matter. The University has allocated sufficient resources to ensure the policy can be adhered to, and an external departmental review process has been put in place to ensure that this situation does not repeat itself.

Finding 2021-008 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $45,129 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 40 individual costs charged to the grant, 26 items tested, all payroll related, did not include adequate documentation. For the payroll items, the University did not provide documentation to support the time and effort of each employee charged to the grant. For 1 nonpayroll related cost, the invoice provided did not have a documented approval. Identification As A Repeat Finding: 2020-007 Recommendation: We recommend that management properly document the internal control over the approval of the invoice. Management should also adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University has re-instated the payroll for compliance with level of effort. All employees paid on a grant will now confirm monthly by signing a compliance form. The University is also implementing a technology solution in collaboration with our payroll partner ADP to automate this process using electronic forms and workflow. The Director of Title III and Compliance and the Comptroller will perform periodic reviews of these activities to ensure that policies are adhered to.

Finding 2021-009 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2020-008, 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring the policies regarding separation of duties are understood and followed by all concerned parties.

Finding 2021-010 ? Material Weakness: Allowable Costs and Activities ? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) section 314(c )(1-3) notes that HEERF Institutional Portion funds are to be used to defray expenses associated with coronavirus or to carry out student support activities that address needs related to coronavirus. Condition: The University charged two invoices for furniture purchases to the HEERF Institutional Portion of the grant that were not allowable per the grant guidelines as the purchases did not defray expenses associated with coronavirus. Cause: Controls over compliance put in place by management did not operate effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: $78,637 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: During the testing performed, it was noted that HEERF Institutional Funds were utilized to purchase furniture. The furniture purchases were not utilized to defray expenses associated with coronavirus but instead were to replacement furniture in offices on campus. The control over compliance to ensure costs charged to the grant were allowable did not operate effectively. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University has existing policies for the review of expenditures against restricted resources. Due to staff challenges this practice was not adhered to. The University has implemented internal controls reconfirming that principal investigators must authorized expenditures where resources under that management are being used. In addition, the Accounting Office has implemented quarterly budget to actual reports and review meetings with principal investigators to review all salary, equipment and expenditures allocated to the grant they have primary oversight.

Finding 2021-011 ? Material Weakness: Allowable Costs and Activities and Period of Performance ? Compliance and Control Finding ALN 84.425J ? Higher Education Emergency Relief Fund (HEERF) HBCU Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is allowed to utilize HEERF funding to reimburse lost revenues associated with room and board and childcare services. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The University did not provide supporting documentation for lost revenues that were reimbursed related to residence halls and childcare services. A second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Documentation was not retained to support the lost revenues amounts for residence halls and childcare services. Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: $685,333 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: During the testing performed, it was noted that HEERF funds were utilized to reimburse the University for lost revenues. The documentation provided to support the lost revenues was not sufficient to determine that the estimated lost revenues was accurate. In addition, there was no control identified to ensure costs charged to the grant were allowable and incurred within the period of performance. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2020-009. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring all concerned parties understand and follow the policies regarding the separation of duties.

Finding 2021-012 ? Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.318, requires grantees have and use documented procurement standards in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over property and service purchases. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $14,500 were purchased under the federal grant without obtaining quotes. Equipment and services totaling approximately $193,000 were purchased under the federal grant without documentation that the vendor was not suspended or debarred prior to entering into the contract. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials: The University has a pre-existing procurement policy. Due to staffing challenges and changes, these policies were circumvented. The University is engaging in procurement department and campus wide training regarding purchasing policies. The University is also identifying all services where new request for proposals are required and putting these services out for bid.

Finding 2021-013 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425 ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per Uniform Guidance, the University is required to complete Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2) and (a)(3) funds. This quarterly report is to include funds from assistance listings 84.425F, 84.425J, 84.425K 84.425L, 84.425M, 84.425N and 84.425S as applicable. The quarterly report is to be posted to the University?s website for each calendar quarter reporting period no later than 10 days after the end of each calendar quarter. In addition, the University is also required to submit an annual report electronically to the Department of Education by February 8, 2021. Condition: The University did not provide proof that the quarterly reports were posted to its website by required date. In addition, the annual report was not submitted by the required submission date. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the HEERF grant timely nor did the University submit the annual report timely as required by the Department of Education. Questioned Costs: Not applicable. Context: The University did not ensure guidelines from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: 2020-010 Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University will date all uploads to the website for the student funding reporting in compliance with existing regulations.

Finding 2021-014 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425E ? Higher Education Emergency Relief Fund (HEERF) Students Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The quarterly reporting form that was required to be utilized for the HEERF institutional portion included specific instructions to include only HEERF funds spent from assistance listings 84.425F, 84.425J, 84.425K 84.425L, 84.425M, 84.425N and 84.425S as applicable. Condition: The University improperly reported $1,096,800 of HEERF student portion costs on the quarterly HEERF institutional reports on the line ?Providing additional emergency financial aid grants to students?. The University was not aware of the requirements to exclude the student portion costs from the quarterly report. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public sufficient information within the HEERF quarterly reports that would allow the public to understand the proper amount and nature of its use of the institutional portion of HEERF. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: Not applicable. Context: The University improperly reported $1,096,800 of HEERF student portion costs on the quarterly HEERF institutional portion reports on the line ?Providing additional emergency financial aid grants to students?. The University was not aware of the requirements to exclude the student portion costs from the institutional portion report. Identification As A Repeat Finding: 2020-011. Recommendation: We recommend that management implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials: The University reported the student portion of expenses with the institutional funding, and only the institutional funding was required. The Comptroller has attended a webinar by the Department of Education to clarify the reporting rules and will comply with them in the future. Brian Freeman, of the Department of Education, told the comptroller to correct this going forward but not to amend prior reports.

Finding 2021-015 ? Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $40,922 of known questioned costs were identified in our testing sample. Likely questioned costs exceed $25,000. Context: For a sample of 40 individual costs charged to the grant, 16 payroll items tested did not include adequate documentation. The University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management retain invoices and receipts for all nonpayroll items charged to the grant. Management should also adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University has re-instated the payroll for compliance with level of effort. All employees paid on a grant will now confirm monthly by signing a compliance form. The University is also implementing a technology solution in collaboration with our payroll partner ADP to automate this process using electronic forms and workflow. The Comptroller will perform periodic reviews of these activities to ensure that policies are adhered to.

Finding 2021-016 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: Not applicable Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring the policies regarding separation of duties are understood and followed by all concerned parties.

Finding 2021-017 ? Material Weakness: Equipment and Real Property Management ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.313{c}, requires grantees have the following in place for equipment purchased with grant funds with a useful life of more than one year and a per-unit acquisition costs which equals or exceeds the lesser of the capitalization policy of the grantee or $5,000: ? Equipment be used in the program for which it was acquired; ? Property records must be maintained that include a description of the property, a serial number or other identification numbers, the source of the funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the projects cots, the location, use and condition of the property, and any ultimate disposition data for the property; ? A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years; ? A control system must be developed to ensure safeguards to prevent loss, damage or theft of the property; ? Adequate maintenance procedures must be developed to keep the property in good condition. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over equipment and real property management and does not have a process in place to ensure federally funded equipment is inventoried. Cause: Management charged with oversight over the federal grant could not support their compliance with these equipment and real property management requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Based on a sample selection of equipment from the capital asset listing, the location for equipment purchased in previous grant years is not property tracked by management. An inventory of all equipment purchased with grant funds has not been adequately completed within the last two years. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management document its equipment and real property management policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. We also recommend that management conduct a physical inventory for all equipment purchased with grant funding. Views Of Responsible Officials: The University is re-introducing an annual inventory process. The University previously conducted a physical accounting of all assets. As a result of staff shortages this process was not completed in recent years. The University is also exploring the use of the Fixed Assets module available within the University?s current ERP system that will allow for the automated management of the fixed asset lifecycle from acquisition to disposal.

Finding 2021-018 ? Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.318, requires grantees have and use documented procurement standards in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: The University did not adhere to the requirements of the Uniform Guidance as noted through procedures performed over property and service purchases. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $11,447 were purchased under the federal grant without obtaining quotes. Equipment and services totaling approximately $33,883 were purchased under the federal grant without documentation that the vendor was properly approved by management before moving forward with the services. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials: The University has a pre-existing procurement policy. Due to staffing challenges and changes, these policies were circumvented. The University is engaging in procurement department and campus wide training regarding purchasing policies. The University is also identifying all services where new request for proposals are required and putting these services out for bid.

Finding 2021-019 ? Significant Deficiency: Eligibility ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per the Student Financial Aid Handbook, Volume 3, the University must follow the eligibility guidelines and limits set by the Department of Education guidelines for awarding Pell Grants and Federal Direct Students Loans. Condition: The University did not properly award students in accordance with the guidelines set by the Department of Education. Cause: Controls over compliance put in place by management were not operating effectively as it relates to awarding and disbursement of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the awarding and disbursement of Title IV funds. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University incorrectly awarded Pell grants for 2 students in the amount of $812 and Federal Direct Loans for 3 students in the amount of $2,964. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The University?s financial policies will be updated, and the calculations will be made in the future. The financial aid staff will be trained to comply with the Title IV policies.

Finding 2021-020 ? Significant Deficiency ? Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Any amount unearned must be returned to the Title IV programs within 45 days. Condition: For a sample of 10 students, it was noted for three students tested the Title IV funds were returned after the 45 day required timeframe. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: During the testing performed, it was noted for three students, the Title IV funds were returned after the 45 day required timeframe. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: 2020-013 and 2019-003 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The University will complete the Return to Title IV (R2T4) calculations weekly with a secondary review and approval control implemented. The University?s financial policies will be updated, and the calculations will be made in the future. The financial aid staff will be trained to comply with the Title IV policies.

.Finding 2021-021 ? Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2020 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $288 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: Based on a sample of 10 students, the University did not exclude a scheduled break of five consecutive days for 6 students tested for the fall 2020 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: 2020-014 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: Due to the institution?s academic calendar change, this calculation was not done previously. The University?s financial policies will be updated, and the calculations will be made in the future. The financial aid staff will be trained to comply with the Title IV policies.

Finding 2021-022 ? Significant Deficiency: Special Tests And Provision ?Disbursements To Or On Behalf Of Students ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program ? Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.164(h)(1), if the Title IV disbursement to a student?s account creates a credit balance, the school must pay the credit balance directly to the student as soon as possible but no later than 14 days after the balance occurred if that was after the first day of class. Condition: The University did not reimburse the students for a credit balance on the student account within 14 days of the date the balance was created. Cause: Controls over compliance put in place by management were not operating effectively as it relates to the disbursement of credit balances. Effect: The University?s controls did not prevent the errors noted during the testing of credit balances on student accounts. Questioned Costs: Known and likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University did not reimburse the students for a credit balance on the student account within 14 days of the date the balance was created. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The University has a documented process to mitigate credit balances not being disbursed to students within the 14 days of the date the balance was created. The Bursar?s Office and Accounting Staff will be trained to comply with the Title IV policies related to student refunds.

Finding 2021-023 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.033 ? Federal Work Study Program ? Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University requested Federal Work Study program funds that exceed the immediate needs of the University. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, the documentation provided indicated that the Federal Work Study program funds were drawn down in excess of the immediate needs of the University. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: Not applicable. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University will implement controls to ensure proper documentation is maintained and reconciled prior to any reimbursement being drawdown from Federal sources. The documents will be reviewed and approved by a separate party from the person performing the cash drawdown to ensure the proper segregation of duties exist.

Finding 2020-002 Material Weakness: Special Tests And Provisions ? Compliance and Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant Program, 84.033 ? Federal Work Study Program, 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.23, the University must submit annually to the Department of Education its compliance audit and its audited financial statements no later than six months after the last day of the University?s fiscal year. The deadline was extended until September 30, 2021 for the audit of the June 30, 2020 compliance audit and audited financial statements. Condition: The University did not meet the Department of Education reporting deadline for the submission of the compliance audit and the audited financial statements. Cause: Controls over compliance put in place by management were not operating effectively Effect: The University?s controls did not prevent noncompliance with the submission deadline for the compliance audit and the audited financial statements. As such, the University has received a citation letter from the Department of Education which resulted in a provisional certification status, the posting of a letter of credit and placement on a heightened cash monitoring payment method for a minimum of five years. Continued noncompliance may result in the Department of Education initiating adverse action against the institution, including terminating or revoking the University?s program participation agreement. In addition, if the University has an application pending for renewal of its certification, the Department of Education may deny the application for continued participation. Questioned Costs: Not applicable Context: The University did not have controls in place to ensure compliance standards were being met. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The FY 2020 audit filings were late due to several unforeseen circumstances, including the impact of COVID 19, leadership changes which included an interim president for one year and a one-year appointed president, the loss of key Accounting Office staff, and the time delays inherent in working remotely to keep people safe. Additionally, based on management review, adherence to institutional policies was compromised due to the need to find stop-gap measures to maintain university operations. While some of the circumstances described above may be understandable, they are not offered as an excuse for the University?s late filings. To remediate this situation, the University has implemented a plan to complete the FY 2020-2021 audit by September 30, 2022. This included updating the DOE notification list. The new President and CFO are now primary contact representatives for the DOE, which will mitigate the chances of similar delays going unaddressed. Additionally, new staff has been hired and trained, all financial policies have been reviewed to ensure compliance with federal and state regulations, and the audit preparation team is now required to provide daily updates to ensure timely submission of the FY21 audit. The daily updates will become weekly updates for the FY22 audit. In May of this year, the University hired a Financial Compliance Officer. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures are in place to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and make recommendations to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-003 Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 - Talent Search and 84.047 - Upward Bound - TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $77,369 of known questioned costs were identified in our testing sample. Projected likely questioned costs exceed $25,000. Context: For a sample of 40 individual costs charged to the grant, 29 items tested (6 nonpayroll and 23 payroll) did not include adequate documentation. For 6 nonpayroll related costs, no receipts or invoices were provided to support the amount charged to the grant. For 23 payroll items, the University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: Not Applicable Recommendation: We recommend that management retain invoices and receipts for all nonpayroll items charged to the grant. Management should also adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University has discontinued the purchase card program, which was used for travel and had supporting documentation shortfalls. The policies for documentation have been reviewed with all employees to confirm understanding. All employees will be accountable for compliance in this matter. Further, the University has re-instated the payroll for compliance with level of effort. All employees paid on a grant will now confirm monthly by signing a compliance form. The Comptroller and the Vice President for Finance and Administration & CFO will perform periodic reviews of these activities to ensure that policies are adhered to. In May of this year, the University hired a Financial Compliance Officer. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-004 Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 - Talent Search and 84.047 - Upward Bound - TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that that entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring all concerned parties understand and follow the policies regarding the separation of duties. While Harris-Stowe?s financial policies comply with state and federal regulatory policies and laws, it is undertaking a comprehensive review to ensure that they are followed, and that University staff have knowledge of them and the institution?s expectations as a part of their duties and responsibilities. The University is also reviewing of its organizational structure and staffing to ensure they are aligned with the University?s policies and expectations for performance and accountability.

Finding 2020-005 Material Weakness: Eligibility and Special Tests and Provisions ? Compliance and Control Finding ALN 84.044 - Talent Search - TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR 643.3 for the Talent Search program requires participants in the program to meet certain eligibility criteria. 34 CFR 643.4(a) requires the program to provide specific services and activities to students participating in the program. Condition: Participant files selected for testing could not be found by management. No control was in place to verify accuracy of participant file documentation and the specific services and activities that are to be provided. Cause: Management was unable to locate files for 5 out of the 28 Talent Search program participants selected for testing. Effect: Without proper documentation of the participant?s eligibility and proof of the specific services and activities provided to students, program noncompliance exists. The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 5 out of 28 files selected for testing, management was unable to provide any information on the student participants in the program. The University did not have internal controls in place to ensure participant file documentation was retained. In addition, no controls excited to ensure support of specific services and activities were documented. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management retain documentation for all participants in the program. We recommend management put a control in place for a review of participant files once eligibility is determined. Views Of Responsible Officials: The University has a policy that was not followed in a timely fashion due to staffing shortages. The Administration has met with the individual department and the appropriate individuals to ensure they understand the policy and what the expectations are regarding compliance. All employees will be accountable for compliance in this matter. The University has allocated sufficient resources to ensure the policy can be adhered to, and an external departmental review process has been put in place to ensure that this situation does not repeat itself. In May 2022, the University hired a financial compliance officer to provide guidance and support to ensure compliance. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-006 Material Weakness: Eligibility and Special Tests and Provisions ? Control Finding ALN 84.042 ? Student Support Services and 84.044 - Talent Search - TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility and determining that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, specifically related to Talent Search and Student Support Services, controls over compliance are not in place as it relates to determining participant eligibility and determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management put a control in place for a second review of the participant files once eligibility is determined and ensure the control also reviews that the required services and activities are being provided. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views Of Responsible Officials: In September of 2020, the University hired an Executive Director of TRIO who is responsible and held accountable for reviewing and approving student participation in the various programs. Additionally, the CFO and Assistant Provost have reviewed the institutional policies and job expectations and have setup a quarterly review to ensure compliance.

Finding 2020-007 Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding ALN 47.076 ? Research and Development Cluster: National Science Foundation ? Implementation Grant: Addressing The Need Of STEM Retention and Missouri Louis Stokes Alliances for Minority Participation Federal Agency: National Science Foundation Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR section 200.403 requires adequate documentation for allowable activities and costs and 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that costs were not supported with adequate documentation. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not operating effectively as it relates to allowable costs and activities charged to the grant. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $65,006 of known questioned costs were identified in our testing sample. Projected likely questioned costs exceed $25,000. Context: For a sample of 40 individual costs charged to the grant, 31 items tested (22 nonpayroll and 9 payroll) did not include adequate documentation. For 22 nonpayroll related costs, no receipts or invoices were provided to support the amount charged to the grant. For 9 payroll items, the University did not provide documentation to support the time and effort of each employee charged to the grant. Identification As A Repeat Finding: Not Applicable Recommendation: We recommend that management retain invoices and receipts for all nonpayroll items charged to the grant. Management should also adjust its time-keeping process to verify that the amount of time charged to the grant is accurate and based on the employee?s time spent working on the grant. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The University has discontinued the purchase card program which was used for travel and which had supporting documentation short falls. The policies for documentation have been reviewed with all concerned employees to confirm understanding compliance. All employees will be accountable for compliance in this matter. Further, the University has re-instated the payroll for compliance with level of effort. All employees paid on a grant will now confirm monthly by signing a compliance form. The Comptroller and the Vice President for Finance and Administration & CFO will perform periodic review of these activities to ensure that policies are adhered to. In May 2022, the University hired a financial compliance officer to provide guidance and support to ensure compliance. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-008 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 47.076 ? Research and Development Cluster: National Science Foundation ? Implementation Grant: Addressing The Need Of STEM Retention and Missouri Louis Stokes Alliances for Minority Participation Federal Agency: National Science Foundation Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that that entity pay for the costs for which reimbursement is being requested. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During testing performed for cash management, appropriate documentation was not retained to provide proof that costs were paid prior to reimbursement. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s requirements. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring the policies regarding separation of duties are understood and followed by all concerned parties. While Harris-Stowe?s financial policies comply with state and federal regulatory policies and laws, it is undertaking a comprehensive review to ensure that they are followed, and that University staff have knowledge of them and the institution?s expectations as a part of their duties and responsibilities. The University is also undertaking a reviewing of its organizational structure and staffing to further ensure that they are aligned with the University?s policies as well as expectations for performance and accountability. Additionally, the University has hired an interim Comptroller to oversee the finance/accounting offices. The Comptroller comes to HSSU with 20+ years of financial services experience including serving as a principal member of an accounting consulting firm specializing in financial statement development and audit preparation. The interim Comptroller garnered significant higher education finance experience as the Associate Vice President of Business and Finance at Morehouse College and as the Executive Director of the Office of Budget & Analysis at the Morehouse School of Medicine. The interim Comptroller primary and immediate priorities will be implementing and institutionalizing audit finding corrective actions?including updating related policies and procedures.

Finding 2020-009 ? Material Weakness: Allowable Costs and Activities and Period of Performance ? Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: During the testing performed, it was noted that HEERF Institutional Funds were utilized to reimburse the University for campus housing refunds. A report of the total amount of campus housing refunds was generated and a journal entry was made to recognize the HEERF institutional funds. There was no control identified to ensure costs charged to the grant were allowable and incurred within the period of performance. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The University has a pre-existing policy of segregation of duties. Due to staffing challenges and changes, these duties were not separated. The University hired a Vice President and CFO in August 2020. As part of the CFO?s responsibilities, he is held accountable for ensuring all concerned parties understand and follow the policies regarding the separation of duties. While Harris-Stowe?s financial policies comply with state and federal regulatory policies and laws, it is undertaking a comprehensive review to ensure that they are followed, and that University staff have knowledge of them and the institution?s expectations as a part of their duties and responsibilities. The University is also reviewing of its organizational structure and staffing to ensure they are aligned with the University?s policies and expectations for performance and accountability. Additionally, the University has hired an interim Comptroller to oversee the finance/accounting offices. The Comptroller comes to HSSU with 20+ years of financial services experience including serving as a principal member of an accounting consulting firm specializing in financial statement development and audit preparation. The interim Comptroller garnered significant higher education finance experience as the Associate Vice President of Business and Finance at Morehouse College and as the Executive Director of the Office of Budget & Analysis at the Morehouse School of Medicine. The interim Comptroller primary and immediate priorities will be implementing and institutionalizing audit finding corrective actions?including updating related policies and procedures.

Finding 2020-010 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425E ? Higher Education Emergency Relief Fund (HEERF) Student Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: In accordance with the Department of Education?s Electronic Announcement dated May 6, 2020 and titled Higher Education Emergency Relief Fund Reporting ? Emergency Financial Aid Grants to Students, the College is required to post a 30-day report on the use of the student portion of the HEERF funding received under the CARES Act to its website. The 30-day report is due 30 days from the date of the award. Condition: The University?s award date for the student portion of HEERF was May 18, 2020, therefore the 30-day student portion initial report was required to be posted to the University?s website by June 18, 2020. The University did not provide proof that the initial report was posted to its website by June 18, 2020. The initial report posted to its website indicates information through July 20, 2020, which was 32 days past the due date. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public its use of the student portion of the HEERF grant timely. Questioned Costs: Not applicable. Context: The University did not ensure communications from the U.S. Department of Education were followed to ensure timely reporting. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: The University will date all uploads to the website for the student funding reporting in compliance with existing regulations.

Finding 2020-011 ? Material Weakness: Reporting ? Compliance and Control Finding ALN 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The quarterly reporting form that was required to be utilized for the HEERF institutional portion included specific instructions to include only HEERF funds spent from the institutional portion. Condition: The University improperly reported $951,000 of HEERF student portion costs on the HEERF institutional portion report on the line ?Providing additional emergency financial aid grants to students? on the report posted for the quarter ending September 30, 2020. The University was not aware of the requirements to exclude the student portion costs from the institutional portion report. Cause: Controls over compliance were not put in place by management as it relates to these compliance requirements. Effect: The University did not communicate to the public sufficient information within the HEERF institutional quarterly report for the quarter ending September 30, 2020 that would allow the public to understand the proper amount and nature of its use of the institutional portion of HEERF. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: Not applicable. Context: The University improperly reported $951,000 of HEERF student portion costs on the HEERF institutional portion report on the line ?Providing additional emergency financial aid grants to students? on the report posted for the quarter ending September 30, 2020. The University was not aware of the requirements to exclude the student portion costs from the institutional portion report. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials: The University reported the student portion of expenses with the institutional funding, and only the institutional funding was required. The Comptroller has attended a webinar by the Department of Education to clarify the reporting rules and will comply with them in the future. Brian Freeman, of the Department of Education, told the comptroller to correct this going forward but not to amend prior reports.

Finding 2020-012 Significant Deficiency: Special Tests and Provision ? Enrollment Reporting - Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is required to report changes to a student?s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days. Condition: Based on sample of 40 students tested, the enrollment status of 2 students was not reported within the 60 day timeframe. One student was reported outside of the required 60 day timeframe and the other student was not reported to the NSLDS at all. Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting. Effect: The University was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring. Questioned Costs: None Context: Based on sample of 40 students tested, the enrollment status of 2 students was not reported within the 60 day timeframe. One student was reported outside of the required 60 day timeframe and the other student was not reported to the NSLDS at all. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: 2019-004 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: While Harris-Stowe?s financial policies comply with state and federal regulatory policies and laws, it is undertaking a comprehensive review to ensure that they are followed, and that University staff have knowledge of them and the institution?s expectations as a part of their duties and responsibilities. The University is also reviewing its organizational structure and staffing to ensure they are aligned with the University?s policies. The University will report to National Student Loan Data System (NSLDS) in the required 60-day timeframe. The financial aid staff will be trained on these requirements. In May of this year, the University hired a Financial Compliance Officer. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-013 Significant Deficiency - Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Any amount unearned must be returned to the Title IV programs within 45 days. Condition: For a sample of 40 students, it was noted for two students tested the Title IV funds were returned after the 45 day required timeframe. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds Questioned Costs: $4,303 of known questioned costs were identified in our testing sample. Projected likely questioned costs exceed $25,000. Context: During the testing performed, it was noted for two students, the Title IV funds were returned after the 45 day required timeframe. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: 2019-003 Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: While Harris Stowe's financial policies comply with state and federal regulatory policies and laws, it is undertaking a comprehensive review to ensure that they are followed and that University staff have knowledge of them and the institution's expectations as a part of their duties and responsibilities. The University is also reviewing its organizational structure and staffing to ensure they are aligned with its policy handbook. The University will return to Common Origination and Disbursement (COD) within the required 45-day timeframe. The financial aid staff will be trained on these requirements. In May of this year, the University hired a Financial Compliance Officer. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2020-014 Material Weakness: Special Tests And Provision ? Return Of Title IV Funds ? Compliance and Control Finding ALN 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2019 semester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $556 of known questioned costs were identified in our testing sample. Projected likely questioned costs did not exceed $25,000. Context: Based on a sample of 40 students, the University did not exclude a scheduled break of five consecutive days for 24 students tested for the fall 2019 semester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the semester. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: Due to the institution?s academic calendar change, this calculation was not done previously. The University?s financial policies will be updated, and the calculations will be made in the future. The financial aid staff will be trained to comply with the Title IV policies. In May of this year, the University hired a Financial Compliance Officer. Primary responsibilities include: ? Developing and leading the institution?s financial compliance and ethics program related to financial administration, financial aid, and federally funded grant and programs. ? Inform best practices and identify program priorities to assess and enhance the effectiveness and efficiency of the institution?s compliance processes and ensure the University complies with all applicable state and federal regulations. ? Identify compliance gaps and propose corrective actions. ? Provide general guidance and support to compliance program areas to ensure effective policies, education, assessments, prevention strategies, and corrective measures to comply with each compliance area?s laws, regulatory requirements, and ethical standards. ? Evaluate emerging compliance trends and recommend to the CFO for implementing best practices to support the continuous improvement of the University?s compliance program.

Finding 2019-002 Special Tests and Provisions ? Disbursements To Or On Behalf Of Student - Control Finding ? Significant Deficiency CFDA 84.268 - Student Financial Aid Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.165, a student receiving Federal Direct Student Loan Program loans must be notified in writing no earlier than 30 days before and no later than 30 days after crediting the student?s account for affirmative confirmation of the following: the anticipated date and amount of the disbursement, the right to cancel all or a portion of a loan and procedures by which the student must notify the school. Condition: Based on a review of a sample of 40 students, it was noted for one student tested, the loan notification occurred one day outside the required 30-day timeframe. For another student tested, no proof of notification was located. Cause: Controls over compliance put in place by management were not operating effectively as it relates to special tests and provisions such a student loan notifications. Effect: The University?s controls did not prevent an error from occurring during the notification of the students within the required 30-day period regarding the loan disbursements. Questioned Costs: None. Context: During the testing performed, we noted for one student the loan notification letter was missing and for another student the loan notification letter was outside of the required 30-day timeframe. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: Not Applicable Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views of Responsible Officials: The University will review its process and controls to ensure that it is appropriate and operating effectively to support compliance with the 30 day requirement.

Finding 2019-003 Special Tests And Provision ? Return Of Title IV Funds - Control Finding ? Significant Deficiency CFDA 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Any amount unearned must be returned to the Title IV programs within 45 days. Condition: Based on a review of a sample of 40 students, it was noted for one student tested, the Title IV funds were returned after the 45 day required timeframe. In addition, for one other student tested, the incorrect amount of Title IV funds were returned. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University?s controls did not prevent the errors noting during the return of Title IV funds Questioned Costs: $332 Context: During the testing performed, it was noted for one student, the Title IV funds were returned after the 45 day required timeframe. In addition, for one other student tested, the incorrect amount of Title IV funds were returned. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: Not Applicable Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views of Responsible Officials: The University will review its process and controls to ensure that it is appropriate and operating effectively to support compliance with the 45 day requirement.

Finding 2019-004 Special Tests and Provision ? Enrollment Reporting - Compliance and Control Finding ? Significant Deficiency CFDA 84.063 ? Federal Pell Grant Program and 84.268 ? Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: The University is required to report changes to a student?s enrollment status and the date the enrollment status was effective and submit the changes to the National Student Loan Data System (NSLDS). The status changes must be reported at a minimum of every 60 days. Condition: Based on a review of 40 students, it was noted that 6 students effective withdrawal date reported to NSLDS did not agree to internal reports provided by management. In addition, for 3 of these students, the student?s status was reported outside of the required 60 day timeframe. Cause: Controls over compliance put in place by management were not operating effectively as it relates to enrollment reporting. Effect: The University was not in compliance with the enrollment reporting guidelines. In addition, the internal controls did not prevent instances of noncompliance from occurring. Questioned Costs: None Context: During the testing performed, it was noted that 6 students effective withdrawal date reported to NSLDS did not agree to internal reports provided by management. In addition, for 3 of these students, the student?s status was reported outside of the required 60 day timeframe. The sample was non-statistical from a listing of students receiving financial aid. Identification As A Repeat Finding: Not Applicable Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views of Responsible Officials: The University will review its process and controls to ensure that it is appropriate and operating effectively to support compliance with the 60 day requirement.

Finding 2019-005 Cash Management - Control Finding ? Material Weakness CFDA 47.076 - Research and Development Cluster - Missouri Louis Stokes Alliance for Minority Participation and Implementation Grant: Addressing the Need of STEM Retention at HSSU Federal Agency: National Science Foundation CFDA 84.042 ? Student Support Services, 84.044 - Talent Search and 84.047 - Upward Bound - TRIO Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Management should have controls in place to review all reimbursement requests and the subsequent cash drawdowns to ensure funds are drawn down from the correct grant. Condition: We noted that management did not have adequate and effective controls over cash management that included the segregation of duties between review and approval. Cause: Controls over compliance put in place by management were not operating effectively as it relates to cash management. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to the aforementioned requirements. Questioned Costs: None Context: During the testing performed, we noted all reimbursement requests are completed and drawn down without a review process. The sample was non-statistical from a list of all cash drawdowns completed during the fiscal year. Identification As A Repeat Finding: 2018-003 Recommendation: We recommend that management implement a control to require a second independent review of all reimbursement requests prior to the subsequent drawdown of funds. Views of Responsible Officials: The University is in the process of hiring a Vice President and Chief Financial Officer in order to review the work of the Comptroller in order to add an independent review of the Comptrollers? work prior to draw down of funds.

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