Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 5, 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 September 5, 2023, which was (1079 days ago).
What is a management decision? →Student Financial Assistant Cluster ALN 84.268 Federal Direct Student Loan Programs U.S. Department of Education Program Year 2021 ? 2022 Criteria or Specific Requirement ? Special Tests and Provisions: Disbursements to or on Behalf of Students, 34 CFR 668.165 Condition ? Eleven students with direct loans were not notified of the date and amount of disbursement and that they have the right to cancel all or a portion of the disbursement. Questioned Costs ? None Context ? Out of the population of 1,527 students who received federal direct student loans, a sample of 27 students was selected for testing. Eleven of the tested students were not correctly notified of the date and disbursement of their direct loans or of the fact that they have the right to cancel all or a portion of the disbursement. Our sample was not and was not intended to be a statically valid sample. Effect ? Eleven students did not receive notifications regarding their direct loans, as required. Cause ? An algorithm in the University?s system was not updated, causing direct loan notifications not to occur for any student not receiving any aid other than direct loans. Identification as a Repeat Finding ? N/A Recommendation ? The University should review its procedures for ensuring that algorithms established in the system are reviewed and updated to ensure all notifications are occurring in compliance with Department of Education guidelines. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and will ensure that all algorithms are reviewed and updated in the future.
Finding 2022-001: Student Notifications a. Comments on Finding and Each Recommendation The University agrees with this finding. Due to turnover in the Student Financial Aid Office algorithms producing automated e-mails were not reviewed and were assumed to work in perpetuity. Action(s) Taken or Planned on the Finding The University has reviewed the Federal notification requirements. The Student Financial Aid office and Campus Technology have met and reviewed the algorithms for notifications and updated the parameters. Additionally, the Student Financial Aid e-mail box has been copied on these notifications and will be reviewed. For inquiries regarding this finding, please contact Christopher Day at (405) 208-5210 who is responsible for the corrective action.
COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Fund ? Student Aid Portion, ALN 84.425E Higher Education Emergency Relief Fund ? Institutional Aid Portion, ALN 84.425F U.S. Department of Education, Award Year 2022 Criteria or Specific Requirement ? Reporting ? Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting and Institutional Aid Portion Quarterly Public Reporting ? 85 FR 53082 Condition ? One of the University?s required public reports for Higher Education Emergency Relief Fund (HEERF) III student aid portion dollars disbursed during the Fall 2021 term and one of the University?s required public reports for HEERF II institutional aid portion dollars were not publicly posted in a timely manner. Questioned Costs ? None Context ? Out of the population of five required quarterly public reports for HEERF I, II, and III student aid portion dollars, one was selected for testing. Out of four required quarterly reports for HEERF I, II, and III institutional aid portion dollars, one was selected for testing. Neither report tested was publicly posted by the stated Department of Education deadline. Our sample was not and was not intended to be a statically valid sample. Effect ? Information required to be made publicly available was not done so in a timely manner, which could result in a loss of funding. Cause ? This was a newer federal program with evolving compliance requirements and, due to turnover in the financial accounting services department in the prior year, current employees were not aware of the requirement. Identification as a Repeat Finding ? 2021-001 Recommendation ? The University should review its processes and controls to ensure awareness of compliance requirements. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and, once made aware, timely filed all required reports.
Finding 2022-002: HEERF II Report Not Published Timely a. Comments on Finding and Each Recommendation The University agrees with this finding. Due in part to turnover in the Financial Accounting Services Department, communications regarding reporting requirements for the student portion of the Higher Education Emergency Relief Funds were not reviewed in a timely manner and public reports were not posted timely. Action(s) Taken or Planned on the Finding The University implemented an internal control whereby the Financial Accounting Services Office posts the public reporting as prescribed by the sponsoring agency. Following a review by the Assistant Controller, the Controller will confirm the posted information is documented as prescribed by the sponsoring agency. This internal control was implemented for the March 31, 2022 quarter public reporting period and completed by April 10, 2022. Past reports were uploaded to the webpage for public reporting. Additionally, the University updated our Department of Education contacts to include the Controller and CFO to prevent future turnover from contributing to noncompliance. For inquiries regarding this finding, please contact Anna Davis at (405) 208-5542 who is responsible for the corrective action.
2021-001
COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Fund ? Institutional Aid Portion, ALN 84.425F U.S. Department of Education, Award Year 2022 Criteria or Specific Requirement ? Procurement and Suspension and Debarment ? Section 18004(a)(1) Institutional Aid Portion ? 2 CFR 200.318-326 Condition ? The University does not have a procurement policy as required under federal guidelines. No support exists to show that vendors are reviewed for suspension or debarment. No support is maintained for sole source purchases. Questioned Costs ? None Context ? The University does not have a procurement policy in place to meet the Uniform Guidance procurement requirements. No errors were specifically found in testing of purchases against federal procurement requirements, but support could not be provided to show University procedures to check suspension or debarment. While none were selected for testing, it was additionally noted that no support was maintained for sole source purchases. Effect ? It is possible that purchases may be made that are not in accordance with federal procurement requirements that could lead to material noncompliance with federal grant agreements. Cause ? The University does not have a procurement policy in accordance with Uniform Guidance in place as is required under federal guidelines. Identification as a Repeat Finding ? N/A Recommendation ? The University should draft and approve a procurement policy that covers all aspects of federal procurement requirements. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and implemented a procurement policy after year-end.
Finding 2022-003: Procurement Policy a. Comments on Finding and Each Recommendation The University agrees with this finding. As a small, private institution with few federal grants a formal procurement policy had not been previously deemed as necessary. In addition, a cumbersome process for approving official University Policies prevented a timely adoption of a Procurement policy once circumstances warranted one. Action(s) Taken or Planned on the Finding The University updated its process for implementing policies in January 2023. The policy committee began meeting in 2023 and is developing a procurement policy for the University that addresses Federal Procurement requirements. For inquiries regarding this finding, please contact Anna Davis at (405) 208-5542 who is responsible for the corrective action.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 13, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 13, 2022, which was (1406 days ago).
What is a management decision? →Criteria: The Coronavirus Aid, Relief, and Economic Security (CARES) Act requires public reporting of specific information pertaining to the Student Aid Portion of funds received pursuant to the Higher Education Emergency Relief Fund (HEERF) provisions of the CARES Act. The HEERF provisions identified as a critical element of that reporting requirement the estimated total number of students at the District eligible to participate in programs under Section 484 I Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act. Condition: The University's required public report for HEERF II student portion of dollars disbursed during the Spring 2021 term was not publicly posted. Cause: The was a new Federal program with new and evolving compliance requirements and there was significant employee turnover in the Financial Accounting Services department. Effect or Potential Effect: The potential effect of excluding the required element from the report is loss of funding. Questioned Costs: None. Recommendation: We suggest management review and update processes and controls to review for changes and updates to compliance requirements. Ensure proper reviews are in place to ensure proper disclosures and reporting are made for each compliance requirement. Management View: Management agrees with the finding.
Comments on Finding and Each Recommendation: The University agrees with this finding. Due in part to turnover in the Financial Accounting Services Department, communications regarding reporting requirements for the student portion of the Higher Education Emergency Relief Funds were not reviewed in a timely manner and public reports were not posted timely. Action(s) Taken or Planned on the Finding: The University will be implementing an internal control whereby the Financial Accounting Services Office will post the public reporting as prescribed by the sponsoring agency. Following a review by the Assistant Controller, the Controller will confirm the posted information is documented as prescribed by the sponsoring agency. This internal control will be implemented for the March 31, 2022 quarter public reporting period and completed by April 10, 2022. Past reports will be uploaded to the webpage for public reporting by February 7, 2022. Additionally, the University will update our Department of Education contacts to include the Controller and CFO to prevent future turnover from contributing to non-compliance. For inquiries regarding this finding, please contact Anna Davis at (405) 208-5542 who is responsible for the corrective action.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 17, 2016. 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 May 17, 2017, which was (3381 days ago).
What is a management decision? →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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