MORRIS COLLEGENon-Profit

2023-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2023 CFDA#: 84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2023 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $250,000 and three quotes for purchases over $10,000. Condition: The College did not follow its procurement policy for the year ended June 30, 2023. We found that disbursements over $10,000 did not have competitive quotes nor purchases of $250,000 were not put out for bid when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $872,309 for Title III and $556,022 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College’s policy meets the standards as noted above. Recommendation: We recommended that management be familiar with procurement polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to the procurement policy

Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2023 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a “physical inventory of the property must be taken and the results reconciled with the property records at least once every two years” and “property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and 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, ...” Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College’s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.

2021-004. Return of Title IV Funds CFDA#: 84.033, 84.007, 84.063, 84.268 Student Financial Aid Cluster Award Year: 2021 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require that, when there are Title IV funds to be returned, that they be deposited or transferred into the student financial aid account or an electronic funds transfer initiated to the Department of Education as soon as possible, but no later than 45 days after the institution determines that a student withdrew. Condition and Context: There was one student where the College failed to initiate the electronic funds transfer to the Department of Education within the 45 day timeframe. We addressed this matter with College management who are aware of the requirements of review of all student withdrawals to determine Title IV refunds and timely return of funds. Effect: Failure to properly review and adhere to policies and procedures can lead to noncompliance and the misappropriation of federal funds that are not detected during the normal course of business. Cause: The lack of compliance is due to the College failing to review student withdrawals in a timely manner. Recommendation: We recommend the College review and update its policies and procedures to ensure all Title IV funds are returned in a timely manner. Auditee?s Response: We concur with the finding. The College is in the process of implementing controls and procedures to ensure that all Title IV funds are properly monitored and reviewed.

Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the GLBA. Schools must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of the federal student aid programs. As part of the GLBA, Morris College is required to designate an individual to coordinate the information security program. The College is required to perform a risk assessment that addresses (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 system failures. The College must also document a safeguard for each risk identified in the assessment. Condition and Context: Morris College has an interim Information Technology Director and has general information system and cybersecurity policies and procedures in place. The College was not aware of the GLBA, nor its requirements, and therefore did not conduct a risk assessment of student financial information vulnerabilities. Cause: Internal controls in the process used by Morris College were not sufficient to demonstrate student financial aid information was being safeguarded effectively. Effects: Noncompliance with the regulations governing Morris College?s federal awards programs could subject the College to additional audits and reviews by the awarding agency and could result (in limited circumstances) in the College having to repay federal awards previously drawn. Questioned Costs: None Recommendation: We recommend the College review its policies and procedures for safeguarding student information, conduct a risk assessment of the areas mentioned above, and enact needed policies to ensure the College is in compliance with the requirements of the Student Financial Aid program. Auditee?s Response: The College?s response is on the corrective action plan.

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