EIN: 660404491
UEI: QMUFKL83DM29
Audited by: J&J CPA, LLC.
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2024. 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 September 30, 2024 (704 days ago).
What is a management decision? →During our Procurement, Suspension and Debarment test, we found 4 instances out a sample of 51 with respect to 84.425F funds and 2 cases with respect to 84.431S on which the proper purchase method was not used by the Institution. Criteria: As per regulation, non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.320 which requires recipients to Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Cause: The Institution followed the small purchase method for these disbursements because there are very few available providers in the island that can deliver the services required and they requested quotes from all known providers, but did not followed the seal bid, competitive proposal or non-competitive proposal (if properly documented) as required by regulations. Effect: Not following established controls could result in non-compliance of federal regulations for the program. Questioned costs: -0- Since the Institution requested quotes from all know providers no cost are questioned for this finding. Recommendation: Procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Show full finding ▾Hide full finding ▴Condition: During our Procurement, Suspension and Debarment test, we found 4 instances out a sample of 51 with respect to 84.425F funds and 2 cases with respect to 84.431S on which the proper purchase method was not used by the Institution. Criteria: As per regulation, non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.320 which requires recipients to Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Cause: The Institution followed the small purchase method for these disbursements because there are very few available providers in the island that can deliver the services required and they requested quotes from all known providers, but did not followed the seal bid, competitive proposal or non-competitive proposal (if properly documented) as required by regulations. Effect: Not following established controls could result in non-compliance of federal regulations for the program. Questioned costs: -0- Since the Institution requested quotes from all know providers no cost are questioned for this finding. Recommendation: Procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Manuals with respect to Procurement procedures will be updated to reflect proper regulation requirements. Also, training will be reinforced with respect to personnel working with purchase procedures to ensure everyone involved in the process is aware of all applicable regulations.
During our Cash Management tests, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Days late 84.425F 3 32/40/46 84.031S 3 10/16/29 84.031M 2 13/15 Criteria: As per regulation, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).With respect to HEERF Section 2 funds the time elapsing between the transfer of funds and the disbursement should be 3 calendar days.Cause: In these instances, for the amount of the service contracted or equipment purchased, the Institution requested the totality of the amount of the service or purchase but, disbursements were made as worked progressed or equipment was completely delivered.Effect: Not following established controls could result in non-compliance of federal regulations for the program.Questioned costs: -0- Recommendation: Cash management procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Show full finding ▾Hide full finding ▴Condition: During our Cash Management tests, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Days late 84.425F 3 32/40/46 84.031S 3 10/16/29 84.031M 2 13/15 Criteria: As per regulation, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).With respect to HEERF Section 2 funds the time elapsing between the transfer of funds and the disbursement should be 3 calendar days.Cause: In these instances, for the amount of the service contracted or equipment purchased, the Institution requested the totality of the amount of the service or purchase but, disbursements were made as worked progressed or equipment was completely delivered.Effect: Not following established controls could result in non-compliance of federal regulations for the program.Questioned costs: -0- Recommendation: Cash management procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Manuals with respect to Cash Management procedures will be updated to reflect proper disbursement procedures in order to comply with regulations. No longer will drawdowns be made for the totality of the services contracted or items purchased unless the related invoice is fully due for payment. In all other cases drawdowns will be made as payments are due
FAC accepted this audit on March 2, 2023 — management decision was due September 2, 2023.
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Show full finding ▾Hide full finding ▴Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
No federal funds are drawn until the suppliers’ banking information is provided and an additional employee is now available to handle disbursements.
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) 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. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Show full finding ▾Hide full finding ▴Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) 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. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Effective immediately, as a condition to issue a payment, all purchases exceeding the federal limit will require (a) evidence that quotes from at least three qualified vendors were obtained or (b) a written and signed statement that there are no other vendors providing the goods or services or (c) a written and signed statement that the purchase was made to address an emergency as declared by federal or local governments.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Show full finding ▾Hide full finding ▴Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Management will be more vigilant and will review future filings before they are published.
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Show full finding ▾Hide full finding ▴Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Since August 2022, the Financial Aid Office has been responsible for enrolment reporting. The contract with the third-party vendor was terminated, and the process was reassigned to the Financial Aid Office. As of August 2022, the Financial Aid Office staff is required to update the roster monthly through the NSLDS website, no later than 15 days after receiving it. The Registrar’s Office generates a graduate student report at the end of each academic period, and the Financial Aid Office updates the student statuses on the NSLDS website.We commit to implementing the corrective plan for this finding by March 31,2025.
FAC accepted this audit on December 20, 2024 — management decision was due June 20, 2025.
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Show full finding ▾Hide full finding ▴Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
No federal funds are drawn until the suppliers’ banking information is provided and an additional employee is now available to handle disbursements.
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) 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. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Show full finding ▾Hide full finding ▴Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) 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. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Effective immediately, as a condition to issue a payment, all purchases exceeding the federal limit will require (a) evidence that quotes from at least three qualified vendors were obtained or (b) a written and signed statement that there are no other vendors providing the goods or services or (c) a written and signed statement that the purchase was made to address an emergency as declared by federal or local governments.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Show full finding ▾Hide full finding ▴Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Management will be more vigilant and will review future filings before they are published.
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Show full finding ▾Hide full finding ▴Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Since August 2022, the Financial Aid Office has been responsible for enrolment reporting. The contract with the third-party vendor was terminated, and the process was reassigned to the Financial Aid Office. As of August 2022, the Financial Aid Office staff is required to update the roster monthly through the NSLDS website, no later than 15 days after receiving it. The Registrar’s Office generates a graduate student report at the end of each academic period, and the Financial Aid Office updates the student statuses on the NSLDS website.We commit to implementing the corrective plan for this finding by March 31,2025.
FAC accepted this audit on March 24, 2022 — management decision was due September 24, 2022.
FAC accepted this audit on March 8, 2021 — management decision was due September 8, 2021.
FAC accepted this audit on February 18, 2020 — management decision was due August 18, 2020.
Criteria 34CFR 675.16(a)(4) FWS Payments to students establishes that Regardless of the student's employer the Institution is responsible for ensuring that the students is paid for work performed. Condition There University has an underpayment of 10 hours to a student for work performed. Questioned Costs: $72.50 Context Out of the twenty-five (25) student files examined for Federal Work Study, one (1) was underpaid $72.50 or 10 hours. Effect The University did not comply with federal statutes for this student employed thru the Federal Work Study Program. Cause An involuntary error on the payroll data created this underpayment to occur. Recommendation The University must paid the owed amount to the student and strengthen its control procedures and diligent and review files to make sure that no required documents are missing or incomplete. Views of Responsible Officials See the University?s Corrective Action Plan for Responsible Officials? Comments
Show full finding ▾Hide full finding ▴Criteria 34CFR 675.16(a)(4) FWS Payments to students establishes that Regardless of the student's employer the Institution is responsible for ensuring that the students is paid for work performed. Condition There University has an underpayment of 10 hours to a student for work performed. Questioned Costs: $72.50 Context Out of the twenty-five (25) student files examined for Federal Work Study, one (1) was underpaid $72.50 or 10 hours. Effect The University did not comply with federal statutes for this student employed thru the Federal Work Study Program. Cause An involuntary error on the payroll data created this underpayment to occur. Recommendation The University must paid the owed amount to the student and strengthen its control procedures and diligent and review files to make sure that no required documents are missing or incomplete. Views of Responsible Officials See the University?s Corrective Action Plan for Responsible Officials? Comments
Involuntarily. An error was made in the entry of student's payroll data, disbursing $72.50 less than the correct amount. The following actions will be taken as corrective measure: (1) The student will immediate be paid the amount due ; (2) The FWS payment process will be assigned to another Financial Assistance officer with more experience in the process and (3) A new reconciliation process will be added, which will be audited by the Bursar's Office Director, to ensure that disbursements are properly allocated.
FAC accepted this audit on February 27, 2019 — management decision was due August 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on March 19, 2018 — management decision was due September 19, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in Puerto Rico →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Add it to a monitored group and get alerted when a new audit, finding, repeat finding, or management-decision deadline shows up — instead of checking back.
Checking several at once? Portfolio view →
© 2026 Single Audit Intelligence. All data is public domain.