Governor of Mississippi 550 High St. Jackson, MS 39201
Re: Annual Submission Citation Letter
Locator School OPE ID: 00239600 Fiscal Year Ended: June 30, 2022
Dear Governor Reeves:
Institutions participating in the Title IV, Higher Education Act programs are required to have annual compliance and financial statements audits (34 C.F.R. § 668.23(a)(2)). The regulations provide that the U.S. Department of Education (Department) will accept audits performed under the Single Audit Act meeting the Department’s audit requirements that are also submitted to the Department within the timeframe established for Single Audits (34 C.F.R. § 668.23(a)(4) and (5)). The regulations at 2 C.F.R. § 200.512(a)(1) establish the deadline for the submission of Single Audits as no later than nine months after the end of the audit period.
Citation for failure to submit acceptable compliance and financial statement audits timely is a past performance violation under 34 C.F.R. § 668.174(a)(3), resulting in, among other things, provisional certification, and placement on a heightened cash monitoring payment method, for a minimum of five years. Further, 34 C.F.R. § 668.171(i) provides that an institution’s failure to submit compliance and financial statement audits by the date and in the manner required under 34 C.F.R. § 668.23 may result in the Department initiating adverse action against the institution, including terminating or revoking the institution’s program participation agreement. In addition, if the institution has an application pending for renewal of its certification, the Department may deny that application for continued participation.
The State of Mississippi and the public institutions making up the School Group subject to audit as part of the state-wide Single Audit have an audit period ending June 30 of each year.1 The June 30, 2022 annual audit submission was due no later than March 31, 2023. However, the audit was not submitted until June 14, 2023. As a result, a letter dated August 4, 2023 was sent to you
1 When more than one institution is subject to audit in a given Single Audit, the Department refers to those institutions as a “School Group.” The Department identifies one institution within a School Group as the Department’s contact for issues concerning the School Group. This institution is the “Locator Institution” for the School Group. The attached listing of institutions is a listing of the public institutions in the state of Mississippi that the Department’s records show as being subject to audit on an annual basis as part of the Mississippi state-wide Single Audit as a School Group. Alcorn State University is the Locator Institution for this School Group .
Atlanta School Participation & Financial Analysis Division
61 Forsyth Street SW, Suite 18T40, Atlanta, GA 30303 C.L48.06.22.2023 State of Mississippi Institutions of Higher Learning OPE ID: 00239600 Page 2 of 4
citing the State of Mississippi’s Institutions of Higher Learning for a past performance violation due to late audit submission.
The Department received a letter from the Mississippi State Commissioner of Higher Education, dated September 26, 2023, with a detailed explanation for the circumstances leading to the late audit submission. The Mississippi State Commissioner of Higher Education explained a compounding effect on the amount of audit work required as a result of significant additional federal dollars approved by congress for state and local governments through the CARES Act, GBLA requirements, the Coronavirus State and Local Fiscal Recovery Fund, and other legislation. Many of these programs were identified as high risk, meaning that the programs required audit coverage in addition to the Federal programs that were to be covered as part of the annual Single Audit without any additional audit resources.
The Department has taken into consideration the underlying factors associated with this late audit submission. The Department accepts Mississippi’s explanation of why the 2022 audit submission was late and has determined that the circumstances around the 2022 late audit submission meet the criteria to be considered unusual in that they are unique to the impact on the overall audit requirements resulting from the Coronavirus Pandemic and the compressed time span available to perform the audit work. Therefore, although all of the institutions in the School Group subject to audit as part of the state of Mississippi state-wide Single Audit for the audit period ending June 30, 2022, are hereby cited for violation of the past performance requirements at 34 C.F.R. § 668.174(a)(3) for failure to submit acceptable compliance and financial statement audits timely, the Department will not impose certain additional conditions on the Title IV participation of those institutions due to the late submission. The impacted Institutions of Higher Learning have been removed from Heightened Cash Monitoring 1 and returned to advance funding. The impacted institutions may contact our office at [email protected] for further information regarding the provisional certification status.
The Department expects that the audit for the audit period ending June 30, 2023 will be submitted in a timely manner as required by the regulations. Please note that any future late submissions may result in the imposition of the citation requirements under 34 C.F.R. § 668.174.
If you have questions or concerns, please contact Vinita Simpson Miller at 202-552-0062 or [email protected].
Sincerely,
Vinita Simpson Miller
Branch Chief Atlanta School Participation and Financial Analysis Division
C.L48.06.22.2023 State of Mississippi Institutions of Higher Learning OPE ID: 00239600 Page 3 of 4
VSM/VSM
C.L48.06.22.2023 State of Mississippi Institutions of Higher Learning OPE ID: 00239600 Page 4 of 4
cc: State of Mississippi Institutions of Higher Learning Emailed to: [email protected] Southern Association of Colleges and Schools Commission on Colleges MS Board of Trustees of State Institutions of Higher Learning Department of Veteran Affairs Department of Defense Consumer Financial Protection Bureau
Institutions under the Mississippi State Audit:
Alcorn State University – OPEID 002396
Delta State University– OPEID 002403 Jackson State University– OPEID 002410 Mississippi University for Women– OPEID 002422 Mississippi State University– OPEID 002423 Mississippi Valley State University– OPEID 002424 University of Mississippi– OPEID 002440 University of Southern Mississippi– OPEID 002441
