University of DelawareNon-Profit

Finding 2024 001: Disbursements: Pell Grant Federal Program Student Financial Assistance Cluster (SFA): Federal Pell Grant Program – ALN 84.063 Federal Agency Department of Education Federal Award Number Award numbers: N/A Federal Award Year July 1, 2023, through June 30, 2024 Finding Type Significant deficiency and other noncompliance Criteria or Requirement In the awarding of Pell grants, Institutions must first identify a defined academic period as defined by the Federal Student Aid Handbook (Volume 3, Chapter 1). The academic year is defined in weeks of instructional time and credit or clock hours. An institution must use the same academic year definition for all federal student aid awards for students enrolled. Under the Federal Student Aid Handbook, there are certain cases where a short, nonstandard term may be combined with a preceding or following term to be considered a single standard term. These are called intersessions. To consider the intersession as being offered in standard terms, it must be combined with either the fall or spring semester and treated as a single term. If not combined, then the intersession must be treated as a non-term program for all federal student aid awards and be calculated under Formula 3 for Pell Grants. Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition Found, including Perspective The University utilizes a standard term calendar and therefore should calculate federal student aid under Formula 1 (Volume 7, Chapter 1). Under Formula 1, institutions generally calculate a student’s Scheduled Award and splits such award evenly between the fall and spring semesters. The University offers a winter intersession, but did not combine the winter intersession with the fall or spring semester as prescribed by the Federal Student Aid Handbook when calculating federal student aid awards under Formula 1. Instead, the University used Formula 3 to calculate Pell Grant awards and treated the winter intersession as a separate term and awarded Pell Grants to students for the Winter 2024 intersession. In 2024, the University identified that such approach did not align with applicable Title IV regulations and Department guidance. By using Formula 3 to calculate Pell Grant awards, the University exceeded the students’ standard Scheduled Award. The total amount of over-awarded Pell Grants for the 2023-2024 academic period was $698,000. Possible Cause and Effect The University misinterpreted Title IV regulations reintroduced with Year-Round Pell and Department guidance, using Formula 3 to calculate Pell Grant awards related to winter intersession while using Formula 1 for the standard terms when Formula 1 should have been used for all terms. Failure to implement sufficient internal controls to verify the University’s award of Pell Grants in accordance with federal regulations increases the risk of noncompliance. Questioned Costs $698,000 Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No Recommendation We recommend the University enhance its internal control over compliance with the federal regulations related to disbursement of Pell Grant awards. The University should enhance how it receives, and processes external information to ensure the University is properly awarding federal student aid in accordance with Title IV regulations and Department guidance. Additionally, a control should be designed and implemented for the review of such information. Views of Responsible Officials The University agrees with the finding. The University identified this issue as a result of an extensive review of processes, procedures and internal controls within Student Financial Services with the assistance of both external consultants and outside counsel. Through the University’s research, it was determined that this issue began in 2018 with the reintroduction of Year-Round Pell. The over-awarded amount resulted from the misinterpretation of the regulations and associated guidance and use of the incorrect formula. The University self-identified the issue with the Department of Education and is working towards resolution. The questioned costs of $698,000 related to fiscal year 2024 were refunded to the government through COD system as of September 30,2024. The University is working with the Department of Education to open prior periods to finalize the repayment of an additional $1.9 million which is expected to be completed by June 30, 2025. The University has implemented internal controls which include the use of the Peoplesoft delivered tools to ensure that Pell is awarded using Formula 1 in accordance with Title IV regulations and Department guidance. The information related to winter intersession aid has been updated to specifically address winter Pell and ensure that it meets required regulations for attaching an intersession to a standard term when using Formula 1 for calculating Pell grant eligibility. Additionally, the University has implemented a weekly reconciliation and over-award reports to monitor for compliance.

Finding 2024-002: Reporting: Pell Grant Disbursement Data Federal Program Student Financial Assistance Cluster (SFA): Federal Pell Grant Program – ALN 84.063 Federal Agency Department of Education Federal Award Number Award numbers: N/A Federal Award Year July 1, 2023, through June 30, 2024 Finding Type Significant deficiency and other noncompliance Criteria or Requirement In the management and reporting of Pell Grants, institutions must submit Pell Grant origination records and disbursement records to the U.S. Department of Education Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. The disbursement record reports the actual disbursement date and the amount of the disbursement. Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition Found, including Perspective In our testing over reporting of Pell Grant disbursement data for the year, we identified a total of twenty- three late submissions of the forty samples reviewed. Possible Cause and Effect The University’s internal control over compliance with reporting Pell Grant disbursement data was not operating consistently through fiscal year 2024, including the timely submission of records. The late submissions occurred when submission files were submitted to COD and received errors. The University Student Financial Services group typically performs disbursement reconciliations every seven days wherein these errors are corrected, however, this schedule was not followed during the fiscal year 2024 due to staff turnover and shortages. The University also historically relied upon a manual process to submit winter Pell awards to the COD system. This led to incorrect sequencing of the Pell awards and resulted in the rejection of these awards when submitted to the COD system. In correcting the winter Pell award process and transitioning to a system-delivered process for summer Pell reporting, transmission was rejected because of a sequencing issue which delayed the summer Pell reporting. Failure to implement sufficient internal controls to verify the University submits Pell Grant disbursement data in accordance with federal regulations increases the risk of noncompliance. Questioned Costs No questioned costs were identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No Recommendation We recommend the University enhance its internal control over compliance with the federal regulations related to reporting of Pell Grant disbursement data. The University should maintain an appropriate level of staffing to properly perform timely reporting of Pell Grant disbursement information to the COD system. The University should also align the internal control process of reporting Pell Grant disbursement data regardless of semester to eliminate manual errors. Views of Responsible Officials The University agrees with the finding. These late reporting stemmed from two issues. The fall and spring delays were related to errors in the reporting file, which caused the disbursements to fail in processing through the COD via the electronic batch process. The Student Financial Services team identified these errors during their reconciliation process, generally completed weekly. However, during part of the last academic year, this schedule was not consistently followed due to staffing issues. In addition to the fall and spring delays, there were delays in reporting summer Pell disbursements. This delay was directly related to correcting the University’s self-identified issue with the awarding and disbursement of funds during the Winter term related to Finding 2024-001. The University has corrected the processing of Pell during the winter term which will eliminate the sequencing issue. Additionally, the University has implemented electronic batch processing to COD for the summer term and addressed staffing issues to ensure that the reconciliation process continues on a weekly basis.

Finding 2023-001: Procurement: Suspension and Debarment Federal Program Research and Development Cluster (R&D) (AL No.: Various) Federal Agency National Institute of Standards and Technology Federal Award Number Award numbers: 70NANB21H085, 70NANB21H086, 70NANB17H002 Federal Award Year July 1, 2022 through June 30, 2023 Criteria or Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain others criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Found, including Perspective In our testing over suspension and debarment, we identified two covered transactions, both with the same vendor, in a sample of 40 procurement transactions for which the University was unable to provide supporting documentation that they verified the vendor was not suspended or debarred prior to entering into the procurement transaction with the vendor. It was determined that the related vendor was not suspended or debarred. Possible Cause and Effect The University’s internal control over compliance with federal procurement suspension and debarment was not operating consistently through fiscal year 2023, including obtaining and maintaining appropriate documentation. Failure to implement sufficient internal controls to verify the University does not enter into covered transactions with parties that are suspended or debarred in accordance with federal regulations increases the risk of noncompliance. Questioned Costs No questioned costs were identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year Yes Recommendation We recommend the University enhance its internal control over compliance with the federal regulations related to suspension and debarment to ensure covered transactions are not entered into with parties that have been suspended or debarred. Views of Responsible Officials The University agrees with the finding. The University has taken additional measures to ensure a clause with suspension and debarment language is included within the contracts of all new covered transactions entered into on or after July 1, 2023. The finding relates to a legacy contract and has prompted a review of open purchase orders to address suspension and debarment requirements. Additionally, the University will begin utilizing a third-party verification software to screen existing and potential vendors against the System for Award Management (SAM.gov) Exclusions list daily, with an expected implementation by June 30, 2024.

Finding 2022-001: HEERF ReportingFederal ProgramCOVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (AL No.: 84.425E)Federal AgencyU.S. Department of EducationFederal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe objective of the Higher Education Emergency Relief Fund (HEERF) program is to use HEERF grantfunds to ?prevent, prepare for, and respond to coronavirus? through grants to eligible institutions. There are three components to reporting for HEERF: (1) public reporting on the (a)(1) Student Aid Portion;(2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. Beginning on May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020.Sections 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Quarterly Public Reporting must be conspicuously posted on the institution?s primary website on the same page the reports of the Institution of Higher Education (IHE)?s activities as to the emergency financial aid grants to students made with fundsfrom the IHE?s allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted.A new, separate form must be posted covering each quarterly reporting period (September 30,December 31, March 31, June 30), concluding after either (1) posting the quarterly report endingSeptember 30, 2022, or (2) when an institution has expended and liquidated all (a)(1) Institutional Portion,(a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which is due October 30, 2020.Condition Found, Including PerspectiveIn the review of the quarterly reporting requirement for the student aid portion, we noted the University did not modify its student aid portion reporting to the quarterly requirement, but rather the University provided updates every 45 days from the date of the first student award made. The University subsequently corrected the reporting in late fiscal year 2022 and posted the quarterly reports; however they were not posted timely, as required. In addition, we noted that the University?s annual report for the year ended December 31, 2021, reported certain data elements that did not agree with supporting documentation.Possible Cause and EffectManagement?s review control over its reporting requirements for HEERF student was not operatingeffectively to ensure compliance with the quarterly reporting and accuracy of annual reporting. Whilemanagement?s reporting in connection with the student portion was more frequent than required, it was not initially in accordance with quarterly requirement, nor was it timely.Questioned CostsNone identified.Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearYes ? 2021-001RecommendationGiven the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF to ensure timely and accurate reporting in accordance with the stated reporting requirements.View of Responsible OfficialsThe University of Delaware (UD or the University) agrees that the evolving guidance created challenges in maintaining compliance. Controls over reporting requirements are expected to function effectively now that the reporting requirements are finalized.The HEERF reporting guidelines final changes required schools to change student reporting from the 15/30-day requirement to quarterly reporting. UD continued to report on a more frequent basis for student reporting. Having conferred with the Department of Education (the Department) contact, UD was required to go back and add the quarterly reports. The required forms were completed and updated on the website in August 2022.The University?s annual report for the year ended December 31, 2021, was submitted in a timely manner. However, the University is required to review and update the reported enrollment and disbursements to students based on a review by the Department. Student Financial Services (SFS) has reviewed the final disbursements as of December 31, 2021, and will only report on those disbursements claimed by students. Unclaimed funds, which have been reallocated to other students, inflated the dollar amount actually provided to students, and will no longer be included. The Department has also provided guidance to the University on the enrollment reporting. The report has been updated and was submitted to the Department of Education during the open period in March 2023.

Finding 2022-002: EquipmentFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementNon-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that:1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).4. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). 5. Adequate maintenance procedures must be developed to keep the property in good condition (2 CFR section 200.313(d)(4))Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, Including PerspectiveThe University did not complete its physical inventory counts for 10 departments out of the 15 sampled University departments. The University has a total of 70 departments monitoring federal equipment. In addition, for one item in our sample of 40 physical inspections, we noted the property was not appropriately tagged for identification.Possible Cause and EffectThe control that equipment purchased on federal grants is counted, and reconciled to property records, within a two-year period was not operating effectively. Further, the control regarding tagging and identifying equipment to the University?s property records was not operating effectively.Questioned CostsNone identified.Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNo.RecommendationWe recommend the University enhance its internal control over compliance around establishing property records of newly acquired federally funded equipment in accordance with applicable Federal regulations, and completing the necessary physical inventories and reconciliations.Views of Responsible OfficialsThe University agrees with the finding and will strengthen processes including unit and senior leadership accountability around the tagging and surveying of federally funded equipment. The University will implement management and escalation procedures with executive leadership to ensure that accountability for all completed surveys resides with the senior leader. The entire process is being evaluated and controls will be enhanced where needed and training will be expanded to include the importance of timely compliance.

Finding 2022-003: Procurement: Suspended and DebarredFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: 1935956, 70NANB20H037, 70NANB17H002, OIA ? 1757353, P20GM113125Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementNon-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over suspension and debarment, we identified nine covered transactions in a sample of 40 procurement transactions for which the University was unable to provide supporting documentation that they verified the vendor was not suspended or debarred prior to entering into the procurement transaction with the vendor. It was determined that the related vendors were not suspended or debarred.Possible Cause and EffectThe University?s internal control over compliance with federal procurement suspension and debarment was not operating consistently through fiscal year 2022, including the maintaining of appropriate documentation.Failure to implement sufficient internal controls to verify the University does not enter into covered transactions with parties that are suspended or debarred in accordance with federal regulations increases the risk of noncompliance.Questioned CostsNo questioned costs were identified.Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance its internal control over compliance with the federal regulations related to suspension and debarment to ensure covered transactions are not entered into with parties that have been suspended or debarred.Views of Responsible OfficialsThe University agrees with the finding. The University will ensure suspension and debarment language is included within the contracts of all new covered transactions effective July 1, 2023 and thereafter.Additionally, the University will investigate utilizing third-party verification software to screen existing and potential vendors against the System for Award Management (SAM.gov) Exclusions list daily with expected execution by July 1, 2024.

Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.

Finding 2021-001: Reporting Federal Program COVID-19 Higher Education Emergency Relief Fund (ALN: 84.425) Federal Agency U.S. Department of Education Federal Award Year July 1, 2020 through June 30, 2021 Criteria or Requirement The objective of the Higher Education Emergency Relief Fund (HEERF) program is to use HEERF grant funds to ?prevent, prepare for, and respond to coronavirus? through grants to eligible institutions. There are three components to reporting for HEERF: (1) public reporting on the (a)(1) Student Aid Portion;(2) public reporting on the (a)(1) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and the (3) the annual report. Beginning on May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. Sections 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Quarterly Public Reporting must be conspicuously posted on the institution?s primary website on the same page the reports of the Institution of Higher Education (IHE)?s activities as to the emergency financial aid grants to students made with funds from the IHE?s allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted. A new, separate form must be posted covering each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after either (1) posting the quarterly report ending September 30, 2022, or (2) when an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which is due October 30, 2020. Condition Found, Including Perspective In the review of the quarterly reporting requirement for the institutional portion, we noted the University did not post their quarterly reports for March 31, 2021 and June 30, 2021 within the 10 day after each quarter end requirement. These reports were posted on October 10, 2021. In the review of the quarterly reporting requirement for the student portion, we noted the University did not modify its student portion reporting to the quarterly requirement, but rather the University provided updates every 45 days from the date of the first student award made. Possible Cause and Effect Management?s review control over its reporting requirements for HEERF institutional and student was not operating effectively to ensure compliance with the requirements. While management?s reporting in connection with the institutional portion was accurate, it was not posted timely. While management?s reporting in connection with the student portion was more frequent than required, it was not in accordance with quarterly requirement. Questioned Costs None identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF to ensure timely and accurate reporting in accordance with the stated reporting requirements. View of Responsible Officials The University agrees with the finding. The HEERF reporting guidelines were in flux throughout the 2021 fiscal year. Final changes required schools to change student reporting from the 15/30 day requirement to quarterly reporting. The University continued to report on a more frequent basis for the student reporting. The University will create and post the quarterly student reports. The institutional reporting has been posted. Controls over reporting requirements will be enhanced.

Finding 2021-002: Gramm-Leach-Bliley Act ? Student Information Security Federal Program Student Financial Assistance Cluster (ALN: 93.364, 84.268, 84.063, 84.038, 84.033, 84.007) Federal Agency U.S. Department of Education Federal Award Year July 1, 2020, through June 30, 2021 Criteria or Requirement The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as `financial institutions? and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) ED provides additional information about cybersecurity requirements at https://ifap.ed.gov/fsa-cybersecurity-compliance. Among the requirements, institutions must: (a) designate an individual to coordinate the information security program; (b) perform a risk assessment that addresses the three required areas noted in 16 CFR 314.4(b), which are (1) employee training and management; (2) information systems, including network and software design as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions or other systems failures; and (c) document a safeguard for each risk identified. Condition Found, Including Perspective In the review of GLBA compliance requirements, we noted the University had performed a formal risk assessment in 2017, however, has not updated the risk assessment annually in accordance with 16 CFR 314.4(b), nor has it updated its safeguard response. Possible Cause and Effect Management?s control over its compliance with GLBA risk assessment and responses was not operating effectively to ensure compliance with the requirements. Therefore, changes to the operating environment that could impact information technology risks may not have been identified and/or safeguard responses may not have been put into place or are not operating effectively. Questioned Costs None identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the finding, and the evolving information security environments and compliance requirements, we recommend management enhance its controls over GLBA risk assessment, which should include an annual review of risks and responses that is reviewed by senior management and discussed with the appropriate board committee. View of Responsible Officials The University agrees with the finding. The University is engaging an independent qualified consultant to conduct the risk assessment and to prepare the risk management plan for GLBA related data, including responses to risks identified. Controls over the annual risk assessment will be enhanced.

Reference Number: 2019-001Federal Agency: VariousProgram Name (CFDA #): Research and Development Cluster (CFDA No. Various)Federal Award Year: July 1, 2018 to June 30, 2019Federal Award Number: 70NANB17H002; DE-AR0000771; P20GM103446-18; W81XWH-11-2-0222; FA9550-14-1-0198; 1507540Compliance Requirement: AllowabilityCriteria or RequirementPer 2 CFR section 200.430(i), salaries and wages charged to Federal awards must be based on records thataccurately reflect the work performed. These records must be (1) supported by a system of internal controlwhich provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(2) incorporated into the official records of the non-Federal entity; (3) reasonably reflect the total activity forwhich the employee is compensated not exceeding 100 percent of compensated activities; (4) support thedistribution of the employee?s salary or wages among specific activities or cost objectives if the employee workson more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a directcost activity; two or more indirect activities which are allocated using different allocation bases; or anunallowable activity and a direct or indirect cost activity; and (5) comply with the established accounting policiesand practices of the non-Federal entity.Additionally, the University has policies that require each effort certification to be completed within ninety (90)days following the end of the reporting period. The University divides each year into three (3) effort reportingperiods: two (2) apply to all salaried employees who are required to report effort and one (1) applies only tofaculty on academic appointments of less than 12 months.Condition Found, including PerspectiveIn 6 of 65 payroll samples selected, the effort certification forms were completed more than 90 days after theend of the University's reporting period, an average of 138 days.Possible Cause and EffectThe University was significantly delayed in sending out the certification forms during fiscal year 2018 and partof fiscal year 2019; therefore, the certifications were not completed timely. The University's monitoring controlover initiating the effort certification process at the end of the reporting period was not operating effectively forthe early portion of fiscal year 2019.Questioned CostsNone.Statistical Validity of SampleThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearYes (2018-001)Recommendation: We recommend the University continuously enhance its monitoring control over the timely initiating andcompletion of the effort certification process.

Reference Number: 2019-002Federal Agency: Department of Health and Human ServicesProgram Name (CFDA #): Research and Development Cluster (CFDA No. Various)Federal Award Year: July 1, 2018 to June 30, 2019Federal Award Number: 14A00216; 1600268; 263001-UD; GR411418; P20GM103446-17;P20GM103446-18; P20GM113125-03; R01AG041202C;R01AG058853A; R01GM080646D; R01HD086362; R01HD087459A;R01HL104106B; R03HD088668A; T32HD007490-18; T32HD007490-19; U54GM104941-05; U54GM104941C; U54GM104941C; UTA16-000683Compliance Requirement: AllowabilityCriteria or RequirementPer 2 CFR section 200.430 provides that Federal agencies may approve alternative methods of accounting forsalaries and wages based on achievement of performance outcomes, including instances where funding frommultiple programs/awards is blended to more efficiently achieve a combined outcome. National Institute ofHealth (NIH) contains restrictions on the amount that can be charged for individual salaries. NIH is the largestbiomedical research agency in the world and part of the U.S. Department of Health and HumanServices (DHHS).Additionally, the University has policies over monitoring DHHS salary cap compliance.Condition Found, including PerspectiveFor 7 of 7 employees sampled with 12 month salaries during fiscal year 2019 that exceeded the corresponding12 month period estimated NIH salary cap, we noted that the University did not monitor whether the salarieswere charged in accordance with the NIH salary cap limit. The University direct charged $459,506 for thoseincluded in the sample during fiscal year 2019. For 5 of 7 employees, we noted fiscal year 2019 compensationcharged, without regard to cost sharing commitments, exceeded the estimated salary cap for the correspondingperiod by approximately $80,000. However, when cost-sharing estimates were considered for the sample of 7,we noted 2 of 7 employees exceeded the estimated salary cap limit by approximately $13,000 in aggregate.Possible Cause and EffectThe University?s monitoring control over the salary cap compliance was not operating effectively during fiscalyear 2019.Questioned CostsKnown questioned costs are estimated to be approximately $26,000, which includes salary charges andestimated fringe benefits and indirect cost recovery.Statistical Validity of SampleThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior Year: NoRecommendationWe recommend the University enhance its monitoring control over compliance with NIH salary cap.

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