EIN: 520591672
UEI: QFHXJFV1UH78
Audited by: RSM US LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (28 days from today).
What is a management decision? →For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Cause: The University had turnover in the registrar’s office during the Fall of 2024 resulting in delays in submitting information to NSLDS. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment information. Questioned costs: None Context: We selected forty students to evaluate reporting of status changes to NSLDS. Out of forty students selected, sixteen student status changes were not reported timely. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives timely information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2025-001 – Special Tests— NSLDS Reporting (Significant Deficiency) Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans) and No. 84.063 (Federal Pell Grant Program) Federal award year 2024-2025 Criteria: CFR Section 685.309 and 690.83(b)(2) requires the University to notify the National Student Loan Data System (NSLDS) within 30 days of a change in student status or include the change in status in a response to an enrollment reporting rosters within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Condition: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Cause: The University had turnover in the registrar’s office during the Fall of 2024 resulting in delays in submitting information to NSLDS. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment information. Questioned costs: None Context: We selected forty students to evaluate reporting of status changes to NSLDS. Out of forty students selected, sixteen student status changes were not reported timely. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives timely information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the finding. The delays in reporting were identified beginning in December 2024 with the hire of a new registrar and since that time we have caught up with reporting requirements are now timely. We have also increased our cross-training efforts in the department, training multiple individuals on NSC reporting procedures, in order to ensure that if turnover were to occur again in the future there are other individuals who can perform the required functions. Person(s) Responsible for Corrective Actions: Katie Soter, Registrar Anticipated Completion Date: Completed
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included 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. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2024-001 – Equipment and Real Property Management Finding: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Corrective Actions Taken or Planned: We agree with the auditors’ findings. Currently, the University’s federally funded equipment inventory consists of 6 pieces of equipment located in the laboratory where they are used on a regular, if not daily, basis, facilitating a regular visual inventory. However, the need to accurately track and document each piece of equipment, in accordance with Federal guidelines, is recognized. Going forward, an annual physical inventory will be taken, during which each piece of equipment will be identified based on the unique serial number as provided by the manufacturer. Documentation will be maintained by the department with an annual inventory supplied to the Dean and Grants Management department. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: completed
The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2024-002 – Procurement and Suspension and Debarment Finding: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with its own procurement policy. Corrective Actions Taken or Planned: We agree with the auditors’ findings. It should be noted that 100 percent of FY2024 equipment purchases were audited, consisting of one piece of equipment. Although the current policy for purchases over $25,000 was followed, the findings were not properly documented. In response, a checklist will be developed through the grants management office,compliance training will be conducted with PIs at the time of grant award and compliance will be implemented by the Dean or respective department head. Policies and procedures will be followed and properly documented for all future purchases of equipment to be funded by federal or state dollars. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: April 30, 2025
The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2024-003 – Procurement and Suspension and Debarment Finding: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. A lack of controls to reasonably ensure this verification was performed. Corrective Actions Taken or Planned: We agree with the auditors’ findings. Correcting actions will be included in the checklist referred to in 2024-002 above. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: April 30, 2025
The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2024-004 – Subrecipient Monitoring Finding: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Corrective Actions Taken or Planned: We agree with the auditors’ findings. A draft policy for assessing risk and monitoring of subrecipients has been circulated within our governance structure and will be implemented thus ensuring compliance through appropriate policies and procedures. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: April 30, 2025
Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.
Identifying Number: 2024-005 – Special Tests – Enrollment Reporting Finding: Student status changes were not reported accurately to NSLDS. The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Corrective Actions Taken or Planned: We agree with the auditors’ findings. NSLDS receives enrollment data from MSMU through the National Student Clearinghouse (NSC). If a student who was previously reported as enrolled is not listed subsequently, NSC will report the student as withdrawn. If MSMU does not update the records on a timely basis, NSC automatically reports to NSLDS that the student has withdrawn, which may not be the case. The errors in the reporting process have been resolved and the appropriate steps are in place to report on a timely basis. Person(s) Responsible for Correction Actions: Boyd Creasman, Provost Anticipated Completion Date: April 30, 2025
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Show full finding ▾Hide full finding ▴2022-001: Cash Management Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the cash management requirement, as summarized in the 2022 OMB Compliance Supplement stipulates that the institutional aid portion of ESF Funds (ALN 84.425F) should be disbursed within 3 calendar days of the drawdown from the G5 system. For lost revenue recovery, the "obligation" occurs on the date the institution completes its estimate of is amount of lost revenue after the estimation period. Condition: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Identifying Number: 2022-001: Cash Management Finding: The University developed several options for calculating lost revenue. The University did not finalize and select from the available options to formally document its final estimate of lost revenue within the required three calendar days after receiving the funds. Corrective Actions Taken or Planned: Management has implemented a Grants Compliance Checklist to assist in adhering to grant requirements. Person(s) Responsible for Correction Actions: William E. Davies, Vice President for Finance and Business, Anne Miller, Controller Anticipated Completion Date: Completed March 24, 2023
The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Show full finding ▾Hide full finding ▴2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Per 2 CFR 200.510(b), the University must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with requirements in 2 CFR 200.502. Condition: The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Identifying Number: 2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Finding: The SEFA initially drafted and provided for formal audit documentation by the University contained all expenditures but was considered incomplete as the definition was expanded to include lost revenues which were not included in the first draft of the report. As a result, this finding is categorized as not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Corrective Actions Taken or Planned: Management has reread the applicable FAQ documents incorporated in the Uniform Guidance regulations related to HEERF III lost revenue documentation and how such funds should be reported on the SEFA, or not reported, as applicable. Person(s) Responsible for Correction Actions: William E. Davies, Vice President for Finance and Business, Anne Miller, Controller Anticipated Completion Date: Completed March 22, 2023
The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Show full finding ▾Hide full finding ▴2022-003: Earmarking Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the ?Matching, Level of Effort, and Earmarking? requirement, as summarized in the 2022 OMB Compliance Supplement states that the American Rescue Plan (ARP) created two specific requirements for the use of the institutional aid portion of ESF Funds (ALN 84.425F). A portion of such funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in Section 479A of the HEA. As noted in Question 35 of the ARP HEERF III ARP FAQs, institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition: The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
Identifying Number: 2022-003: Earmarking Finding: The University did not earmark an allocated share of expenses to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines in the SEFA related to the ESF grant as required by the regulations. Corrective Actions Taken or Planned: Management has implemented a Grants Compliance Checklist to assist in adhering to grant requirements. Person(s) Responsible for Correction Actions: William E. Davies, Vice President for Finance and Business; Anne Miller, Controller Anticipated Completion Date: Completed March 24, 2023
FAC accepted this audit on July 31, 2022 — management decision was due January 31, 2023.
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on December 14, 2018 — management decision was due June 14, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
FAC accepted this audit on November 9, 2017 — management decision was due May 9, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 13, 2016 — management decision was due June 13, 2017.
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