EIN: 660432514
UEI: JTFKX11JLHS8
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 26, 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 December 26, 2026 (128 days from today).
What is a management decision? →Program Student Financial Assistance (SFA) Cluster – Various ALNs Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. There are two categories of enrollment information “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting all Campus-Level Record and Program-Level Record data elements. Institutions are responsible for timely reporting. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. The institution must update for changes in the data elements for the Campus Record and the Program Record and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended,; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Out of a sample of 33 students, 4 had a status change that was not reported to the National Student Loan Data System (NSLDS). Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-003 (continued) Cause Processes and controls over the reporting of the student status change to the Department of Education are not properly designed or not functioning as intended to ensure that the University complies with this requirement. Effect The University did not comply with the enrollment reporting requirements, which may result in inaccurate or incomplete enrollment data in NSLDS and limit the Department of Education’s ability to monitor student eligibility and loan status. Questioned Costs Not applicable. Context We performed a test of detail where our statistically valid sample consisted of 33 items from a population of 221 students that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period. Based on the evidence examined, we noted 4 samples in which no reporting of enrollment data was provided to the National Student Loan Data System (NSLDS). Identification as a repeat finding, if applicable 2020-015 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.
To ensure UVI remains compliant with federal regulations tied to Title IV aid, monthly enrollment reporting, graduation reporting, and internal controls & compliance will be adhered to, which will ensure financial aid compliance protects institutional eligibility for Title IV funding to maintain the integrity of UVI’s academic and financial reporting.
2020-015
Federal Program Education Stabilization Fund – ALN 84.425E, 84.425F, 84.425J, 84.425H Compliance Requirement Reporting Criteria The Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP) Act institutional quarterly reporting requirements involve publicly posting completed forms on the institution’s website. The forms must be conspicuously posted on the institution’s primary website on the same page as the reports of the Institution of Higher Education (IHE) activities related to the emergency financial aid grants to students (Student Aid Portion). A new, separate form must be posted covering aggregate amounts spent for Higher Education Emergency Relief Fund (HEERF I), HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all Institutional Portion funds and checks the “final report” box. IHEs must post this quarterly report no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). The Governors (Outlying Areas) reporting requirements involve a monthly report related to all expenditures of the issued award by the Government of the United States Virgin Islands. Condition Out of a sample of 10 performance and special reports, 5 were submitted past the established due date, and 4 were not submitted. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports. Effect The University did not comply with reporting requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-004 (continued) Context We performed a test of details using a statistically validated sample of 10 items selected from a population of 25 performance and special reports. Based on the evidence examined, we identified 5 samples in which reports were issued after the required submission deadline and 4 samples in which no reporting was provided to the direct recipient, the Government of the United States Virgin Islands. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.
The Controller will work with the Grant Accountants to implement and document internal controls and procedures to ensure that all Federal financial reports are completed, reviewed, and submitted in a timely manner. These procedures will include requirements for maintaining supporting documentation as evidence that the control process was followed. Additionally, the accounting team will ensure that all Grant Accountants have access to the necessary reporting modules to prevent any reports from being overlooked.
2020-017
Federal Program Smith Lever Extension – 10.511 Compliance Requirement Reporting Criteria Recipients must use the Federal Financial Report (FFR) as a standardized format to report expenditures under federal awards and submit them in a timely manner. Condition Two instances in which the control intended to ensure timely submission failed to prevent reports from being submitted after the due date. Cause Controls intended to ensure compliance with reporting timeliness requirements do not appear to be adequately designed or operating effectively. Effect Ineffective controls over the timely submission of FFRs increase the risk of delayed or incomplete reporting and may result in future noncompliance with federal reporting requirements. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-005 (continued) Context We performed a test of details to evaluate the timeliness of FFR submissions. Our sample consisted of 2 items, representing the full population of FFRs required to be submitted during the audit period. Based on the procedures performed, we identified 2 instances in which the reports were submitted after the required due date, with an average delay of approximately 33 days, indicating that controls over the timely submission of FFRs were not operating effectively. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.
The Controller will work with the Grant Accountants to implement and document internal controls and procedures to ensure that all Federal financial reports are completed, reviewed, and submitted in a timely manner. These procedures will include requirements for maintaining supporting documentation as evidence that the control process was followed. Additionally, the Accounting team will ensure that all Grant Accountants have access to the necessary reporting modules to prevent any reports from being overlooked.
2020-017
Federal Program Small Business Development Centers – 59.037 Compliance Requirement Reporting Criteria Recipients must submit Performance Progress Reports using standard form PPR which includes a narrative statement that details all project accomplishments for the reporting period, including a comparison between actual accomplishments and those predicted in the project goals and milestones, and any lessons learned, best practices, notable success stories, problems encountered, and steps taken to address problems. Also, recipient must use the FFR as a standardized format to report expenditures under federal awards and submit them in a timely manner. Condition Out of a sample of 6 performance and special reports, 1 was submitted past the established due date, and 2 were not submitted. Out of a sample of 2 FFRs, 1 was submitted past the established due date. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports. Effect The University did not comply with reporting requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-006 (continued) Context We performed a test of details using a statistically validated sample of 6 items selected from a population of 8 performance and special reports, and a sample of 2 items selected from a population of 4 FFRs. Based on the evidence examined, we identified 2 samples in which reports were issued after the required submission deadline and 2 samples in which no report was submitted. Identification as a repeat finding, if applicable 2020-017 Recommendation We recommend the University implements internal controls and procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.
Management will reinforce internal controls and procedures to ensure that all required Performance Progress Reports (PPRs) for the Small Business Development Centers program are completed, reviewed, and submitted timely. Responsibilities will be clearly assigned to program and fiscal personnel, reporting deadlines will be tracked using a formal reporting calendar, and reports will be subject to timely supervisory review prior to submission. Supporting documentation will be retained in accordance with federal record retention requirements to evidence compliance.
2020-017
Federal Program Economic Adjustment Assistance - 11.307 Requirement Special Tests and Provisions – Wage Rate Requirements Criteria All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than the established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work was performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition Out of a sample of 6 construction contracts, none had the prevailing wage rates clause. Cause Processes and controls over the inclusion of the prevailing wage rates clause do not exist. Effect The University did not comply with the applicable wage rate requirements, leading to regulatory non-compliance. Questioned Costs Not applicable. Context We performed a test of detail where our statistically validated sample consisted of 6 items from a population of 6 construction contracts. Section III – Federal Award Findings and Questioned Costs (continued) Finding Number: 2021-007 (continued) Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University implements internal controls and procedures to ensure the prevailing wages rate clause is included in all applicable construction contracts. Management’s Response The University of Virgin Islands concurs with this finding. Management response is included in a separate document.
The University will implement internal controls and procedures to ensure that the prevailing wage rate clause is included in all federally funded construction contracts in compliance with applicable regulations. The Principal Investigator (PI) will collaborate with Purchasing & Contracts (P&C) and the Office of Sponsored Programs (OSP) on construction-related projects and will be responsible for flagging the prevailing wage requirement during the planning phase. The Purchasing Department will ensure the clause is included in all solicitations and bid packages for applicable projects. The Project Manager (PM) will be responsible to review all submitted bids to verify that minimum standards, including federal prevailing wage requirements, are met. Finally, the prevailing wage clause will be explicitly incorporated into the final contract and associated Purchase Orders (POs) to ensure full compliance with federal grant conditions and U.S. Department of Labor regulations. This process ensures consistency, accountability, and compliance across all units involved in construction.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 11, 2023. 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 March 11, 2024, which was (892 days ago).
What is a management decision? →Finding Number: 2020-008 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Information on Federal Program(s) ? Small Business Administration Direct Program: Small Business Development Centers CFDA Number: 59.037 U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 U.S. Department of Education Direct Program: Higher Education Emergency Relief Fund CFDA Number: 84.425E, 84.425F, 84.425J Criteria or Specific Requirement ? 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The University did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2020. Questioned Costs ? Not applicable. Context ?This is a condition identified per review of the University?s compliance with specified requirements for 1 of 1 annual reporting. Effect ? The University was not in compliance with the reporting requirements and could be exposed to a reduction or elimination of funds by the federal awarding agencies. Cause ? The University did not have administrative and internal control oversight in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the University enhance its procedures and internal controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The University remains committed to and is focusing its efforts towards timely submission of the Data Collection Form and Reporting Package.
Finding Number: 2020-009 Prior Year Finding Number: N/A Compliance Requirement: Cash Management Information on Federal Program(s) - Small Business Administration Direct Program: Small Business Development Centers CFDA Number: 59.037 Criteria or Specific Requirement ? The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In addition, 2 CFR section 200.305(b) requires that non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. 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. Condition ? The University did not minimize the time elapsing between the receipt of a $320,000 advance for COVID-19 related expenses and the disbursement of the funds to the various vendors. The advance was received on February 15, 2020, and had not been expended by September 30, 2020. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 1 of 3 selected cash drawsdown for cash management testing out of a population of 5. The sampled total was $517,547 out of a population total of $837,547. Effect ? The University is not compliance with the stated provisions. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? We recommend that the University comply with the specified requirements and enhance its procedures and internal controls to ensure that they minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement for program costs. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The Interim Controller will ensure that the Director of Accounting for Grants and Contracts proactively monitors the receipt of advanced funds and ensures that the funds are timely disbursed for program costs or returned to the grantor agency if not expended. The Interim Controller will also ensure that waivers or updated award documents are received from the grantor, to serve as evidence of changed terms.
Finding Number: 2020-010 Prior Year Finding Number: N/A Compliance Requirement: Procurement and Suspension and Debarment Information on Federal Program(s) - Small Business Administration Direct Program: Small Business Development Centers CFDA Number: 59.037 Criteria or Specific Requirement ? The Uniform Guidance in 2 CFR Section 200.318-326, General Procurement Standards, requires that recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements. Condition ? In our review of 8 out of 25 procurement transactions, we noted the following: ? All of the 8 selected procurement transaction files did not contain sufficient supporting documents in order to verify the contractors? exclusion from the Excluded Parties List System to validate the procurement decisions made. ? There is no evidence of issuance of Request for Proposal for 2 out of 8 samples tested. ? In 1 of 8 samples reviewed, there was no evidence of quotations that had been obtained, or sole source justification before a vendor was selected. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 8 of 8 selected procurements. We reviewed 8 procurement files with expenditures totaling $194,350 out of the population totaling $284,366 for fiscal year 2020. Effect ? The University is not compliance with the stated provisions and could inadvertently contract with or make sub-awards to parties that are suspended or debarred from doing business with the Federal government. In addition, failure to perform procurement procedures in accordance with University?s documented policies and Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? We recommend that the University enhance its procedures and internal controls to ensure adherence to Federal regulations relating to the procurement of goods and services and review current records retention policies. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The Director of Purchasing will review the controls established for procurement at the University, and consistently apply the controls established to all purchases. Additionally, the Director of Purchasing will review all purchases considered sole source to validate the required justification is secured before moving forward with the purchase, and all necessary supporting documents are secured, and verification processes are completed before submitting for final processing. Also, all Grant Accountants will perform a review of the vendor invoices received for processing, to confirm the vendor is properly not included on the Excluded Parties List System on sam.gov.
Finding Number: 2020-011 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions - Borrower Data and Reconciliation Information on Federal Program(s) - U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 Criteria or Specific Requirement ? Institutions must report all loan disbursements and submit required records to Common Origination and Disbursement (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. Condition ? During our review, we noted the following: ? We selected 25 samples for testing and noted that 1 sample had not been reported within the 15 days as per the COD reporting timeline. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 1 of 25 disbursements selected for testing. Total fiscal year 2020 loan disbursements were $3,234,152. Effect ? The University is not compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? The University should immediately undertake a process to review its procedures and internal controls to ensure that they comply with the requirements of Title IV aid. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
Financial Aid will conduct an internal comparative analysis of Banner student disbursements to the extracted batch records for transmission to COD to ensure no student records are skipped during the extraction process.
Finding Number: 2020-012 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions - Federal Perkins Loan Liquidation Information on Federal Program(s) - U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 Criteria or Specific Requirement ? As per the compliance supplement, an institution that decided to stop participating in the Federal Perkins Loan program (Perkins) (CFDA 84.038), the institution is responsible for returning any unspent funds (34 CFR section 668.14(b)(25)). The institution must perform the end-of-participation procedures in which it must (a) notify ED of the intent to stop participating in Perkins (34 CFR section 668.26(b)(1)); (b) inform ED of how the institution will provide for the collection of any outstanding loans made under the program (34 CFR section 668.26(b)(4)); (c) purchase any outstanding loans left in its Perkins portfolios or assign them to ED (34 CFR sections 674.8(d), 674.17(a)(2), and 674.45(d)(2)); and (d) maintain program and fiscal records of all Perkins funds since the most recent Fiscal Operations Report (FISAP) was submitted, and reconcile this information at least monthly (34 CFR section 674.19(d)). Condition ? There was no documentation provided supporting whether the University had ceased to participate in the Perkins loan program and had properly performed the end-of-participation procedures or not. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample. Effect ? The University is not compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? The University should immediately undertake a process to review its procedures and internal controls to ensure that they comply with the parameters stated in the Compliance Supplement. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The University is actively working with the U.S. Department of Education to pay off outstanding loan balances not previously turned over to the USDOE. To further implement the recommendation, the University?s Director of Accounting for Operations will conduct a reconciliation of loan balances previously turned over to the USDOE and will subsequently conduct reconciliations monthly. In addition, the University is in contact with the USDOE and a third-party loan servicing provider to determine whether the University previously performed end of participation procedures, and if not, to ensure compliance with such procedures.
Finding Number: 2020-013 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions - Disbursement to or on behalf of Students (Loan Disbursement Notification Testing) Information on Federal Program(s) - U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 Criteria or Specific Requirement ? The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student?s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition ? We sampled and selected 25 out of 1,309 files and noted no evidence provided that students or parents have been notified in writing of the date and amount of the disbursement, no earlier than 30 days before and no later than 30 days after a disbursement. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 25 of 25 students selected for testing. Total fiscal year 2020 loan disbursements were $3,234,152. Effect ? The University is not in compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? The University should immediately undertake a process to review its procedures and internal controls to ensure that they comply with the parameters stated in the Compliance Supplement. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The University has identified the following steps to be implemented to address the finding, as outlined: When Direct Loan funds are being credited to a student?s ledger account, the school will also notify the borrower in writing (paper or electronically) of the ? anticipated date and amount of the disbursement ? student?s or parent?s right to cancel all or a portion of a loan, loan disbursement and have the loan proceeds returned to the Department; and ? procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or loan disbursement.
Finding Number: 2020-014 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions - Disbursement to or on behalf of Students (Federal Work Study Program) Information on Federal Program(s) - U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 Criteria or Specific Requirement ? The student?s wages are earned when the work is performed. The institution shall ensure that the student is paid at least once per month. The federal share must be paid by check or similar instrument the student can cash on his or her endorsement, or as authorized by the student, by crediting FWS funds to a student?s account or by EFT to a bank account designated by the student. The institution may only credit the account for tuition, fees, institutional room and board, and other institution-provided goods and services (34 CFR 675.16). Condition ? We sampled and selected 18 out of 179 work study students? timesheets and noted 2 timesheets were not approved/certified by the student?s supervisor in accordance with the internal control and compliance requirements. Questioned Costs ? Below reporting threshold. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 2 of 18 students timesheets selected for testing. The total amount of expenditures charged to the program during fiscal year 2020 were $53,865. The total sampled amount was $5,244. The known amount of the 2 timesheets amounted to $660. Effect ? The University is not in compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? The University should immediately undertake a process to review its procedures and internal controls to ensure that they comply with the parameters stated in the Compliance Supplement. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
New Timesheets will be created for the 2023-24 aid year to identify the specific types of work study programs and new routing processes. All timesheets being transmitted electronically via email to Payroll must be forwarded/copied to the Offices of Career and Placement Services and Financial Aid. ? Timesheets will be amended with specific headings i.e., Federal Work-study Program/Title IV Aid with a notation of the routing process. ? No Payroll Authorization will occur without a Valid Timesheet being on file at the payroll office. ? For check and balances, once a timesheet is received it will be matched and placed with the student record of appointment in the Offices of Career and Placement Services and Financial Aid.
Finding Number: 2020-015 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Information on Federal Program(s) - U.S. Department of Education Direct Program: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268 Criteria or Specific Requirement ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, 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 (2) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. (34 CFR 685.309(a)(2) and 34 CFR 682.610(c)(2)) Condition ? We sampled and selected 39 out of 383 students that had changes in their enrollment status and noted that 5 out of 39 students? enrolment status had been reported or certified beyond the required 60-day period. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample. Effect ? The University is not in compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? The University should immediately undertake a process to review its internal control procedures to ensure its compliance with the parameters stated in the Compliance Supplement. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The University will review the reports deemed late and work with NSLDS to ensure the files are accurately reported. The University will also strengthen controls related to the Enrollment Reporting Process by reviewing best practices and implementing any necessary changes to the current process.
Finding Number: 2020-016 Prior Year Finding Number: N/A Compliance Requirement: Procurement and Suspension and Debarment Information on Federal Program(s) - U.S. Department of Education Direct Program: Higher Education Emergency Relief Fund CFDA Number: 84.425E, 84.425F, 84.425J Criteria or Specific Requirement ? The Uniform Guidance in 2 CFR Section 200.318-326, General Procurement Standards, requires that recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements. Condition ? In our review of 4 out of 8 procurement transactions, we noted 2 samples totaling $40,491 did not have evidence of sole source justification before a vendor was selected. Questioned Costs ? $40,491. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 2 of 4 selected procurement transactions for testing. We reviewed 4 procurement files with expenditures totaling $218,696 out of the total population of $237,497 for fiscal year 2020. Effect ? The University is not compliance with the stated provisions. Failure to perform procurement procedures in accordance with University?s documented policies and Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? We recommend that the University enhance its procedures and internal controls to ensure adherence to Federal regulations relating to the procurement of goods and services. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The Director of Purchasing will review the controls established for procurement at the University, and consistently apply the controls established to all purchases. Additionally, the Director of Purchasing will review all purchases considered sole source to validate the required justification is secured before moving forward with the purchase, and all necessary supporting documents are secured, and verification processes are completed before submitting for final processing. Also, all Grant Accountants will perform a review of the vendor invoices received for processing, to confirm the vendor is properly not included on the Excluded Parties List System on sam.gov.
Finding Number: 2020-017 Prior Year Finding Number: N/A Compliance Requirement: Reporting Information on Federal Program(s) - U.S. Department of Education Direct Program: Higher Education Emergency Relief Fund CFDA Number: 84.425E, 84.425F, 84.425J Criteria or Specific Requirement ? Each institution must file various financial, programmatic, and special reports. Additionally, the requirements necessitate that all submitted reports should be supported by the underlying performance records and presented in accordance with program requirements. Condition ? We selected and reviewed 3 reports out of a population of 3 submitted during the fiscal year and noted the following: ? 2 reports did not agree to the underlying financial records. ? 3 reports did not contain evidence of review and approval prior to submission. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of the University?s compliance with the specified requirements using a statistically valid sample for 3 of 3 reports selected for testing. Effect ? The University is not in compliance with the stated provisions and inaccurate information may have been reported to the Federal government. Cause ? It appears that administrative and internal control oversight were not functioning as intended. Recommendation ? We recommend the University enhance its procedures and internal controls to ensure proper retention, monitoring, and review of the required reports by an appropriate official to ensure that information submitted is complete, accurate, consistent, and submitted within the required timeframe. Views of Responsible Officials ? The University concurs with the auditor?s findings and recommendations. The planned corrective actions are presented in the University?s Corrective Action Plan which is attached as Appendix B to the Single Audit Report.
The Interim Controller will work with the Director of Accounting for Grants and Contracts to ensure that there is an appropriate, documented review process for Federal financial reports. Specifically, the Director will ensure that the grant accountants are cognizant of the reporting requirements and the special terms and conditions associated with a grant and that financial and other reports comply with the special terms and conditions. In addition, the Interim Controller will ensure that the grant accountant who prepares the financial report affixes his/her signature or initials; and the Director similarly affixes his signature or initials subsequent to a review of the report.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 30, 2021. 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 July 30, 2021, which was (1847 days ago).
What is a management decision? →Finding No. 2019-003 Significant Deficiency in Internal Controls over Compliance and Compliance with Special Reporting Requirements. CFDA No. 84.063 Federal Pell Grant Program Criteria 34 CFR 668.22 states that an Institution must refund the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the Institution?s determination that the student withdrew as defined in paragraph (1) (3) of this section. Condition Of the eight students dropouts that required refunds to the Department of Education, we noted that in three (3) occasions the return was realized after the required time limit of forty-five 45 days. Cause The University did not follow its internal controls and procedures in place to ensure the refunds to the Department of Education were accurate and in time. Effect Non-compliance with timeframe requirement can be interpreted by the awarding agency as failure to follow the established procedures regarding the return of Title IV and may result in imposing of sanctions or other adverse actions. Questioned Costs None Recommendation The University of the Virgin Islands should immediately undertake a process to review its internal control procedures to ensure that they comply with the parameters stated in the Compliance Supplement. View of responsible officials The University concurs with this finding. Previously students did not have access to withdraw from their courses directly. Students were required to visit the Registrar's office and complete a withdrawal form. This form needed to be signed by the professor on file for each course based on the date of withdrawal. The Registrar's office has implemented an online process where students will now be able to withdraw from classes online using BanWeb through mycampus.uvi.edu. Students will have the option to withdraw online or in person without the signatures of the professors. The signature of the Dean will be required for administrative withdrawal. Additionally, weekly updated withdrawal list would be sent to Financial Aid, as well as weekly reports on grade changes. Responsible official Mrs. Moriah Jacobs, Director of Financial Aid
The University concurs with this finding. Previously students did not have access to withdraw from their courses directly. Students were required to visit the Registrar?s office and complete a withdrawal form. This form needed to be signed by the professor on file for each course based on the date of withdrawal. The Registrar?s office has implemented an online process where students will now be able to withdraw from classes online using BanWeb through mycampus.uvi.edu. Students will have the option to withdraw online or in person without the signatures of the Professors. The signature of the Dean will be required for Administrative Withdrawal. Additionally, Weekly updated withdrawal list would be sent to Financial Aid, as well as weekly reports on grade changes.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 27, 2019. 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 December 27, 2019, which was (2428 days ago).
What is a management decision? →Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 16, 2018. 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 April 16, 2019, which was (2683 days ago).
What is a management decision? →Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 29, 2017. 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 December 29, 2017, which was (3156 days ago).
What is a management decision? →GSA_MIGRATION
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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.
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