2022 Audit of the Bridgewater State University Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Bridgewater State University

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of Bridgewater State University (BSU) for the period March 1, 2020 through March 31, 2021.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective	Conclusion
Did BSU administer the student portion of funding under Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act in accordance with Question 13 of Section C; Question 18 of Section D; and Questions 19, 20, 23, 25, and 26 of Section E within the United States Department of Education’s (US DOE’s) Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document?	Yes
Did BSU administer the institutional portion of funding under Sections 18004(a)(1) and 18004(a)(2) of the CARES Act in accordance with Questions 30, 31, 33, 41, and 44 of Section F within US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document?	Yes
Did BSU administer the student portion of funding under Section 314(a)(1) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) in accordance with Questions 7, 8, 11, 15, 24, and 27 within US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs ([Catalog of Federal Domestic Assistance, or CFDA] 84.425E and 84.425F) Frequently Asked Questions?	Yes
Did BSU administer the institutional portion of funding under Sections 314(a)(1) and 314(a)(2) of the CRRSAA in accordance with Questions 10, 15, 18, 19, and 24 within US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions?	Yes
Did BSU administer Governor’s Emergency Education Relief (GEER) funding in accordance with Questions A16, A17, and A18 of US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund) and/or “Attachment A—Terms of Performance and Justifications” within its interdepartmental service agreement (ISA) with the Massachusetts Department of Higher Education (MDHE)?	Yes
Did BSU adhere to Sections 6.2.3 and 6.2.4 of the Executive Office of Technology Services and Security’s (EOTSS’s) Information Security Risk Management Standard IS.010 with regard to cybersecurity awareness training?	No; see Finding 1
Did BSU update its internal control plan (ICP) to address the 2019 coronavirus (COVID-19) pandemic, in accordance with the Office of the Comptroller of the Commonwealth’s (CTR’s) “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020?	Yes

 

To achieve our objectives, we gained an understanding of BSU’s internal control environment related to our objectives by reviewing applicable BSU policies and procedures, as well as conducting inquires with BSU management. We evaluated the design and implementation of controls over BSU’s Education Stabilization Fund grant administration and its ICP.

We determined whether BSU administered the student portion of funding under Section 18004(a)(1) of the CARES Act in accordance with Question 13 of Section C; Question 18 of Section D; and Questions 19, 20, 23, 25, and 26 of Section E of US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document. We also determined whether BSU administered the student portion of funding under Section 314(a)(1) of the CRRSAA in accordance with Questions 7, 8, 11, 15, 24, and 27 of US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions. To do this, we identified a total population of 2,365 students who received emergency financial aid grants, totaling $5,919,013, from BSU during our audit period. They received the grants in the form of refunds. From the population of 2,365 students, we selected a statistical, random sample of 40, with a 95% confidence level, a 0% expected error rate, and a 7.5% tolerable error rate. The total amount of the emergency financial aid grants associated with our sample was $126,220. For each of the students in our sample, we determined the following:

• whether the student filed a Free Application for Federal Student Aid (FAFSA) or, if no FAFSA was completed, whether the student (1) was a citizen; (2) had a valid Social Security number; (3) had registered with the United States Selective Service; and (4) had a high school diploma, a general educational development transcript, or proof of completion of high school in an approved homeschool setting
• whether the student had requested funding for expenses resulting from COVID-19-related disruption of campus operations
• how the emergency financial aid grant was made to the student (by check, electronic transfer, debit card, or payment software)
• that the student was not enrolled exclusively in online courses as of March 13, 2020
• that BSU had not reimbursed itself for providing the student with an emergency financial aid grant based on room and board, tuition, or other activity fees
• that the student was not a student worker at a campus job
• that BSU did not pay the student’s outstanding or overdue student bills
• whether BSU provided the same amount of emergency financial aid to the student with CRRSAA funding that it was required to provide with CARES Act funding
• whether BSU gave priority to the student if the student had exceptional need
• whether the emergency financial aid grant was given on a condition of future enrollment or used to satisfy a student account balance
• whether the emergency financial aid grant was requested for student support activities, to the extent that those activities addressed needs related to COVID-19
• whether the emergency financial aid grant made under the CRRSAA also followed CARES Act guidelines
• whether the emergency financial aid grant was awarded to the student no later than one year after March 11, 2021
• whether the emergency financial aid grant was used to satisfy student account charges posted before December 27, 2020.

We determined whether BSU administered the institutional portion of funding under Sections 18004(a)(1) and 18004(a)(2) of the CARES Act in accordance with Questions 30, 31, 33, 41, and 44 within Section F of US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document. We also determined whether BSU administered the institutional portion of funding under Sections 314(a)(1) and 314(a)(2) of the CRRSAA in accordance with Questions 10, 15, 18, 19, and 24 within US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions. To do this, we identified a total population of 6,970 students who received emergency financial aid grants, totaling $9,328,555, from BSU during our audit period. They received the grants in the form of refunds or adjustments to their account balances. From the population of 6,970 students, we selected a statistical, random sample of 40, with a 95% confidence level, a 0% expected error rate, and a 7.5% tolerable error rate. The total amount of the emergency financial aid grants associated with our sample was $47,004. For each of the students in our sample, we determined the following:

• whether the student’s emergency financial aid grant was a refund to the student or a financial adjustment to the student’s account balance
• whether the student’s emergency financial aid grant was the result of disruptions to campus operations due to COVID-19
• whether the student’s emergency financial aid grant was made on or after March 27, 2020
• whether the student’s emergency financial aid grant was used for boarding, tuition, or other fees as a result of changes due to COVID-19
• that the student’s emergency financial aid grant was not used to pay for employees working in dining halls or dormitories
• that the student’s emergency financial aid grant was not used to cover losses of revenue
• that the student’s emergency financial aid grant was not the result of indirect costs being incurred
• that the student’s emergency financial aid grant was only charged to the institutional portion of the CARES Act or CRRSAA grants
• that the student’s emergency financial aid grant could be reconciled to BSU’s Student Transfer Summary Report
• that the student’s emergency financial aid grant was made no later than one year after March 11, 2021.

To determine whether BSU administered GEER funding in accordance with Questions A16, A17, and A18 of US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund) and/or “Attachment A—Terms of Performance and Justifications” within BSU’s ISA with MDHE, we obtained a population of all 45 custodians, who were paid a total of $165,910 through GEER funding for working during four pay periods when BSU was closed during the COVID-19 pandemic. We selected a nonstatistical, random sample of 15 of the 45 custodians. The total amount paid to the custodians in our sample was $55,234. We obtained all relevant timesheets and payroll registers for the custodians in our sample and determined the following:

• whether payroll expenses were accurately entered in BSU’s Higher Education COVID-19 Response Grant Program Expenditure Report
• whether timesheets showing hours worked matched the related payroll registers
• whether the payroll expenses complied with BSU’s ISA with MDHE
• whether the payroll expenses were related to institutional support for activities related to personnel, payroll, security, environmental health, or safety
• whether the custodians were paid using GEER funding during the audit period.

We also obtained all six paid invoices (totaling $465,665) for COVID-19 molecular testing fees. We determined the following:

• whether the invoice dates were during our audit period
• whether the invoices had adequate descriptions of services rendered
• whether the expenditures identified on the invoices were accurately entered in the Higher Education COVID-19 Response Grant Program Expenditure Report
• whether the expenditures on the invoices complied with BSU’s ISA with MDHE
• whether the expenditures on the invoices were related to institutional support for activities related to personnel, payroll, security, environmental health, or safety
• whether the invoices were paid using GEER funding during the audit period.

To determine whether BSU adhered to Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 with regard to cybersecurity awareness training, we asked members of BSU management who were responsible for such training whether BSU had ensured that all employees received initial and annual cybersecurity awareness training during the audit period.

To determine whether BSU updated its ICP to address COVID-19 in accordance with CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” we inspected the 2020 and 2021 Internal Control Questionnaires (ICQs) that BSU submitted to CTR. We reviewed the ICQ questions that addressed COVID-19 preparedness, as well as the aforesaid guidance. We reviewed the most recent BSU ICP to determine whether BSU had made updates to address COVID-19 in accordance with the guidance and whether the ICP was dated upon its update.

We used a combination of nonstatistical and statistical sampling methods for our audit objectives and did not project the results from the samples to the populations.

Data Reliability

We reviewed the BSU computer network system’s general information system access controls. We also obtained a list of users who had access to the financial module of Banner,² verified their access privileges, and verified their employment with BSU by tracing their names to a list of all BSU employees that was produced by the state’s Human Resources Compensation Management System (HR/CMS) to determine the reliability of the data on the Banner list. We observed BSU’s associate vice president of finance querying Banner for all student-portion disbursements of emergency financial aid grants given under Section 18004(a)(1) of the CARES Act and Section 314(a)(1) of the CRRSAA and extracting 4,838 rows of data. We conducted interviews with BSU officials who were knowledgeable about the data. We inspected the data for hidden rows and columns, embedded data, and invisible content. From the 4,838 rows, we identified 2,365 students who received emergency financial aid grants. We randomly selected a sample of 20 of these students and traced them to a list of all registered students during our audit period to determine whether all 20 were registered BSU students during that period. We reconciled the emergency financial aid grant amounts to amounts in US DOE’s grant management system.

We observed BSU’s associate vice president of finance querying Banner for all institutional-portion disbursements and adjustments of emergency financial aid grants given under Sections 18004(a)(1) and 18004(a)(2) of the CARES Act and Sections 314(a)(1) and 314(a)(2) of the CRRSAA and extracting 22,434 rows of data. We conducted interviews with BSU officials who were knowledgeable about the data. We inspected the data for hidden rows and columns, embedded data, and invisible content. From the 22,434 rows, we identified 6,970 students who received emergency financial aid grants. We randomly selected a sample of 20 of these students and traced their emergency financial aid grants to Individual Student Transaction Summary Reports³ to verify that the students’ accounts received financial adjustments. We also traced the 20 students to a list of all registered students during our audit period to confirm that the students from our sample were BSU students. We reconciled the emergency financial aid grant amounts to amounts in US DOE’s grant management system.

We obtained from BSU’s associate vice president of finance BSU’s Higher Education COVID-19 Response Grant Program Expenditure Report for all the university’s GEER funding, which totaled $631,575 ($165,910 for custodians who performed duties related to the COVID-19 pandemic and $465,665 for COVID-19 molecular testing). We contacted the senior advisor for finance and administration at MDHE and confirmed the $631,575 amount. We obtained from BSU’s associate vice president of finance a list of all the aforesaid custodians. We traced these 45 custodians to an HR/CMS-generated list of all BSU employees to verify that they were employed by BSU during our audit period. We traced the $465,665 for COVID-19 molecular testing from BSU’s Higher Education COVID-19 Response Grant Program Expenditure Report for the GEER funding to all six of the invoices for the testing.

Based on the results of our data reliability assessments, we determined that the information obtained for our audit period was sufficiently reliable for the purpose of our audit objectives.

2.    Banner is the database system BSU uses to manage student information, finances, financial reporting, and other aspects of financial processes.

3.    BSU generates this type of report from Banner. The report provides details of all financial transactions involving a student’s account.

Date published:	June 14, 2022