2022 June 23 Audit Committee Meeting - University System of New ...

2022 June 23 Audit Committee Meeting

June 23, 2022 at 12:15 PM (EST)

University of New Hampshire-Durham

Memorial Union Building, Strafford Room

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A. Approve Minutes of March 3, 2022 Meeting

1. UNH Financial Aid Data Verification Process Audit Report.pdf - 8

B. Accept Internal Audit Reports Issued

1. AC 03-03-2022 DRAFT minutes.pdf - 4

12:15-12:20 pm VV. . Approval of Consent Agenda ItemsApproval of Consent Agenda ItemsMOVED, that the Consent Agenda Items be approved.

1. FY21 Uniform Guidance Single Audit Presentation.pdf - 53

A. Accept External Auditors' FY21 Uniform Guidance Single Audit Reporton USNH Federal Expenditures (15 mins)MOVED, on recommendation of the Chief Administrative Officer, thatthe University System of New Hampshire Auditors’ Reports from CLAfor the year ended June 30, 2021, as required by Title 2 of the U.S.Code of Federal Regulations Part 200, Uniform AdministrativeRequirements, Cost Principles, and Audit Requirements for FederalAwards and Government Auditing Standards and Related Informationbe accepted.

B. Approve Enterprise Risk Management (ERM) Annual Report andAssignment of Risks (15 mins)MOVED, on recommendation of the Chief Administrative Officer, thatthe Audit Committee recommends to the Executive Committee theadoption of the following motion:MOVED, on recommendation of the Audit Committee, the ExecutiveCommittee hereby formally assigns the top 10 system wide risksidentified in the GY 2023 annual ERM report to the appropriate Boardcommittees, as specified in the attachment, for purposes of oversight.

C. Approve FY23 Meeting Schedule and Work Plan (10 mins)MOVED, on recommendation of the Chief Administrative Officer, thatthe Audit Committee FY23 Meeting Schedule and Work Plan beapproved.

2. Uniform Guidance Single Audit motion sheet and report.pdf - 58

1. ERM Annual Report, assignment of risks and motion sheet.pdf -132

12:20-1:00 pm VIVI. . Items for Committee Consideration and ActionItems for Committee Consideration and Action

II. . Meeting InformationMeeting InformationPhysical location:University of New Hampshire-DurhamMemorial Union Building, Strafford RoomCall in: 1 301 715 8592Meeting URL: https://unh.zoom.us/j/97109086215 Meeting ID: 971 0908 6215

IIII. . Audit Committee MembersAudit Committee MembersAlexander Walker, Chair, Gregg Tewksbury, Vice Chair, M. JacquelineEastwood, Shawn Jasper, Mackenzie Murphy, Governor Sununu

IIIIII. . In the Unlikely Event of a Zoom Call FailureIn the Unlikely Event of a Zoom Call FailureCall: 1 877 228 3100Participant Code: 638408

IVIV. . Call to OrderCall to Order

2. UNH Athletics Cash Carrying and Depositing Audit Report.pdf -28

Meeting Book - 2022 June 23 Audit Committee Meeting

MEETING AGENDA - June 23, 2022 at 12:15pmMEETING AGENDA - June 23, 2022 at 12:15pm

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1. EHS Presentation.pdf - 147

A. Receive USNH Environmental Health and Safety Council’s 2021annual report (15 mins)

B. Self-assess Audit Committee Effectiveness (5 mins)

C. Review Audit Committee Charter (5 mins)

D. Review status of outstanding audit issues (5 mins)

2. EHS 2021 Annual Report.pdf - 160

1. Audit Committee Self-evaluation Results 2022.pdf - 286

1. AC Charter with summary sheet.pdf - 289

1:00-1:30 pm VIIVII. . Items for Committee Consideration and DiscussionItems for Committee Consideration and Discussion

A. Chair or Committee comments

B. Next scheduled meeting: October 20, 2022 at Keene State College

IXIX. . Other BusinessOther Business

1. FY23 Meeting Schedule and Work Plan.pdf - 143

1. Status of outstanding audit issues and summary sheet.pdf - 294

VIIIVIII. . Non-Public Session (if needed)Non-Public Session (if needed)

C. Adjourn

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BOARD OF TRUSTEES

p. 1 of 4

AUDIT COMMITTEE MARCH 3, 2022

KEENE STATE COLLEGE

KEENE, NEW HAMPSHIRE and

BY ZOOM MEETING: HTTPS://UNH.ZOOM.US/J/91662457599

MEETING MINUTES

Draft for Approval Committee members physically present: Chair Alexander Walker, Gregg Tewksbury, M. Jacqueline Eastwood, Shawn Jasper, Mackenzie Murphy Other Trustees physically present: Alana Lehouillier Other participants participating by videoconference: (USNH) Tia Miller, Francine Ndayisaba, Christine Heise; (USSB) Sarah Jefferson; (CLA) Andy Lee, Luke Winter Other participants participating in person: (USNH) Ashish Jain, Kara Bean; (UNH) Wayne Jones, Marcel Vernon; (Governor’s Office) Jonathan Melanson I. Call to Order At 12:47 p.m., Committee Chair Walker called the meeting to order. Chair Walker called the roll and noted the presence of a quorum sufficient for the conduct of business. II. Approval of Consent Agenda Items Chair Walker asked the committee members if they had any comments or questions about the consent agenda items; there were none. On motion offered by Trustee Tewksbury and duly seconded, the committee voted to approve the consent agenda. Items on the consent agenda appear below:

A. Minutes of October 22, 2021 Meeting B. Internal Audit Reports Issued:

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https://unh.zoom.us/j/91662457599

Audit Committee p. 2 of 4

1. UNH Spaulding Hall Project Cost Review Report 2. UNH Student Grades Audit Report 3. UNH Garage Inventory Audit Report 4. GSC Student Identity and Financial Verification Audit Report 5. PSU Financial Aid Data Security Review Report

C. Accept UNH NCAA Agreed Upon Procedures Report D. ERM Update on Change Management, Campus Safety, and Compliance

III. Items for Committee Consideration and Action

A. Approve appointment of CliftonLarsonAllen (CLA) as external auditors and

CLA’s Fiscal Year 2022 audit plan covering USNH financial statements and federal awards under the Uniform Guidance

Mr. Lee reviewed the audit scope and deliverables, responsibility overview, audit timeline, and audit fees. The timeline is consistent with prior years and the fees are consistent with the original proposal. Mr. Lee encouraged the committee to contact him if they have suggestions for other focus areas. Mr. Winter discussed risk assessment, fraud considerations, governance input, and new accounting standards. Data analysis is performed to detect trends. Discussions are held with management and their input is encouraged. Mr. Winter discussed Leases GASB No. 87, a new accounting standard effective for the year ending June 30, 2022, which will likely be a heavy undertaking for USNH. He also briefly discussed Replacement of Interbank Offered Rates GASB 93 (effective 2022) and Subscription-Based Information Technology Arrangements GASB 96 (effective 2023). Chair Walker thanked CLA and USNH management for their work. The committee did not have any questions for CLA. The following motion was made by Trustee Tewksbury, duly seconded, discussed, and approved with no votes abstained or dissenting.

VOTED, on recommendation of the Chief Administrative Officer, that CliftonLarsonAllen LLP be confirmed as the external auditor for the University System of New Hampshire to provide audit services related to activities of fiscal year ending June 30, 2022. B. Approve CY22 Internal Audit Plan/Review Internal Audit's CY21 Annual Report

Ashish Jain, USNH Director of Internal Audit, reviewed the CY 2021 annual report and CY 2022 internal audit plan. Information was provided regarding department resources, CY2021 audits, activities, advisory reports and services, organization of the department, budget, staff profiles, and 2021 planned versus actual activities, and current year initiatives. The focus of the CY2022 audit plan will be cash carrying and depositing process at campuses.

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Mr. Jain noted that funds to support an IT Auditor will be available in FY23. Department activities in CY2021 included audits and advisory services, construction cost reviews (outsourced), and data analysis projects. In addition, the department maintained the Ethics and Compliance Hotline, and coordinated ERM reporting, GLBA Compliance Program changes and proposals for GASB 87 and 96 implementation assistance. Effective December 2022, annual reporting to the Board will be required under GLBA. Internal Audit staff is actively involved in many professional organizations (IIA, ACUA, Ivy+), conferences, and associations to keep current in their work and profession. Notably, the Senior Auditor co-presented at ACUA annual conference and co-authored a paper on data acquisition, preparation, and validation. In response to a question from Trustee Tewksbury regarding adequate resources, Mr. Jain noted that while resources may not be ideal, he feels well-supported by management and the Audit Committee. He anticipates that the search for an IT Auditor could be challenging given the market condition. The following motion was made by Trustee Eastwood, duly seconded, discussed, and approved with no votes abstained or dissenting.

VOTED, on recommendation of the Chief Administrative Officer, that the proposed Internal Audit Plan for CY22 be approved.

V. Items for Committee Consideration and Discussion

A. Internal Audit Charter Review The Audit Committee has the responsibility to review and assess the adequacy of the Internal Audit Charter on an annual basis and recommend any changes to the Board. The Internal Audit Charter was last revised in April 2017. No changes to the Internal Audit Charter are recommended by USNH staff at this time.

B. Review status of outstanding audit issues Mr. Jain noted that the list of outstanding audit issues (as of December 31, 2021) includes all significant open issues from past audit reports and those that were closed since the report was last distributed to the Audit Committee. It is updated semi-annually for follow-up and control monitoring purposes. Of 89 action plans currently being tracked, 22 are from internal audit reports issued since the last semi-annual update and six have been reported by management as resolved. The remaining 61 action plans are in process, much improved, on hold, and/or management has accepted the residual risk. Audit issues are monitored and followed up on, especially those that are high risk. In response to a question from Trustee Tewksbury regarding the number of outstanding audit issues, Mr. Jain noted that while progress is being made, the list is growing. Chair Walker

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encouraged Mr. Jain to notify the committee of any issues that cause delays in the resolution of audit issues.

C. Ethics and Compliance Hotline and Fraud Reports Summary Mr. Jain briefly reviewed the process and noted that the hotline is maintained by EthicsPoint. He informed that the hotline complaints are promptly handled while working with campus contacts. In response to a question from Chair Walker, Mr. Jain noted that the hotline information is well advertised (published in bulletins, website, word of mouth, noted in Internal Audit Department’s email signature). Mr. Jones added that UNH publishes hotline information on student websites and other student publications. In response to a question from Mr. Vernon, Mr. Jain stated that initial reports are distributed to CFOs due to low number of reports. Chair Walker felt that the report volume is low considering the size of USNH. Mr. Jain will work with campus leaders to further advertise the hotline. VI. Other Business In response to question from Trustee Tewksbury, Mr. Jain stated that most audits are reviewed and issued by the Internal Audit Department versus outsourcing, noting the importance of consistency and internal knowledge. The department often applies this knowledge to other audits. There will be no April meeting. Chair Walker noted that agenda items for the June meeting include the ERM annual report, Environment Health and Safety annual report, the committee’s self-assessment, conflict of interest process update, and the committee’s work plan. There being no further business, the meeting adjourned at 1:33 p.m.

-- End of Audit Committee Meeting Minutes --

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Internal Audit | 5 Chenell Drive, Suite 301, Concord, NH 03301 | usnh.edu

University of New Hampshire

Financial Aid Data Verification Process Audit

Report issued April 27, 2022

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April 27, 2022 James W. Dean Jr., President University of New Hampshire Durham, New Hampshire 03824

Dear President Dean: This letter conveys our report on the audit on the University of New Hampshire Financial Aid Data Verification Process. As communicated in our engagement letter of August 2, 2021, the primary objective of the audit is to obtain reasonable assurance on the effectiveness on internal controls established to comply with the Department of Education’s verification requirements and whether the existent internal controls are efficient, effective, and operating as expected. This report reflects our observations, which were discussed with members of UNH management, and their action plans in response to our recommendations. It is being distributed to the individuals listed below and will be presented to members of the Audit Committee of the University System of New Hampshire (USNH) at its next scheduled meeting. It is also available for review by external auditors of USNH. We appreciated the full cooperation and assistance we received from Jill Sikora, Associate Director of Financial Aid with whom Christine Heise, Senior Internal Auditor, worked most closely as she conducted the fieldwork for this audit. Please feel free to contact me with any comments, questions, or suggestions you may have. Sincerely,

Ashish Jain Director of Internal Audit

Distribution: Joel Carstens, Director of Financial Aid, UNH Pelema Ellis, Vice Provost of Enrollment Management, UNH Wayne Jones, Provost and Vice President for Academic Affairs, UNH Catherine Provencher, Chief Administrative Officer and Vice Chancellor for Financial Affairs and Treasurer, USNH Steve Schissler, Interim Director, Student Financial Services, UNH

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University of New Hampshire Financial Aid Data Verification Process Audit

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I. Executive Summary We performed an audit of the University of New Hampshire financial aid data verification process. We noted missing key financial aid policies and procedures to consistently and appropriately handle financial aid verifications, professional judgement interpretations, special circumstances, conflicting information, and FAFSA corrections and updates. These policies and procedures are necessary to comply with the Title IV requirements. As a result, we noted issues related to the student notification for verification and related requirements, reporting verification results and professional judgement adjustments to the Department of Education, and calculation errors for revised FAFSA data elements. We also noted inadequate and missing supporting documentation for verification, special circumstances, and corrections to FAFSA data. We recommend management to develop formal financial aid policies and procedures and provide training to the Financial Aid staff. We also noted that UNH should enhance existing financial aid system configurations and develop protocols for handling changes thereto. Due to inaccurate system configurations, we noted instances where student records were not properly categorized, tracked, reviewed, and reported to comply with federal financial aid verification requirements. Management should evaluate and modify the financial aid system configuration to align with current financial aid processes. We noted that management did not have documentation to support the testing of annual changes to the system configurations. We recommend that management develop formal procedures for the periodic testing, review, and approval of changes to system configurations. Supporting documentation should be maintained for the testing, review, and approval. Going forward, management should develop protocols for review and modification of system configurations. Moreover, Financial Aid staff should be trained on USNH Cybersecurity Acceptable Use policies. We noted that a senior staff’s login credentials were used by a student worker for performing financial aid transactions. We also noted that management should review and restrict Banner authorizations for appropriateness and alignment with the job responsibilities. Finally, we noted the opportunity to reduce sensitive data from financial aid forms. Management should modify financial aid forms to include the least amount of personally identifiable information required for routing and review of documentation. II. Background The University of New Hampshire Financial Aid Office assists students in identifying financial aid programs to best meet their financial needs to support their education. There are various types of financial aid available to student including federal aid, state aid, institutional scholarships, and private student loans. Title IV – Federal Financial Aid To apply for federal financial aid, students complete the Free Application for Federal Student Aid (FAFSA). In order to be eligible to receive federal student aid, a student must: (1) be a

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citizen or eligible noncitizen of the United States, (2) have a valid social security number, (3) have a high school diploma or a General Education Development (GED) certificate, or have completed homeschooling, (4) be enrolled in an eligible program as a regular student seeking a degree or certification, (5) maintain satisfactory academic program, (6) not owe a refund on a federal student grant or be in default on a federal student loan, (7) register with the Select Service System, if you are a male and not currently on active duty in the U.S. Armed Forces, and (8) not have a conviction for the possession or sale of illegal drugs for an offense that occurred while you were receiving federal student aid. The FAFSA is processed by the Department of Education Central Processing System (CPS). This system uses the FAFSA information to calculate each applicant’s expected family contribution. After processing the FAFSA, the CPS produces an Institutional Student Information Record (ISIR), which is issued to the institution. This record shows the student’s applicant data, expected family contribution (EFC), and whether the student was selected for verification. The verification tracking flag on a student’ ISIR identifies which applicant data elements an institution must verify for that student. Student eligibility depends on a student's expected family contribution (EFC), year in school, enrollment status, and the cost of attendance (COA). The EFC is based upon the information submitted by a student on the FAFSA and determines a students’ eligibility for certain types of federal student aid. FAFSA Verification Each year the Department of Education selects student FAFSA’s for verification to confirm that the data reported on the FAFSA form is accurate. When a student is selected for verification, the institution is responsible for obtaining and verifying documentation that supports information reported on the financial aid application. There are various verification groups identified by the Department of Education that identifies the items to be verified.

2021/2022 – FAFSA Verification Group

2021/2022 - Items to Be Verified

V1 – Standard Verification Group: Tax Filer

AGI, U.S. income tax paid, untaxed portions of IRA distributions, untaxed portions of pensions, IRA deductions and payments, tax-exempt interest income, education credits, household size, and number in college

V1 – Standard Verification Group: Non-Tax Filer

Income earned from work, household size, number in college

V4 - Custom Verification Group High school completion status and identity/statement of educational purpose

V5 – Aggregate Verification Group All items from V1 standard verification group, high school completion status, and identity/statement of educational purpose

34 CFR 668.57 stipulates the forms of acceptable documentation to be obtained by an institution to support the above listed items for verification. According to 34 CFR 668.53, the Department of Education stipulates that schools must have written policies about (1) the time period in which students must submit verification documentation, (2) the consequences for failing to submit those documents in time, (3) the method you use to notify students if their expected family contribution (EFC) and Title IV aid

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amounts change, (4) the procedures you or students follow to correct the FAFSA data, and (5) the procedure you follow to refer a student to the Office of Inspector General (OIG). In addition, according to 34 CFR 667.54 (a), if an institution has reason to believe that an applicant’s FAFSA information is inaccurate, it must verify the accuracy of that information. An institution may require an applicant to verify any FAFSA information that it specifies. On July 13, 2021, the Department of Education issued GEN-21-05 stipulating changes to the 2021-2022 verification requirements. To provide relief to students and colleges, the Department of Education waived verification on V1 FAFSA verifications. Students and colleges were still required to verify students in the V4 and V5 verification groups. This waiver applied no matter where institutions were in the verification process. However, this change does not exempt institutions from reviewing all documents for conflicting information concerning a student’s eligibility. During the 2021-2022 financial aid year, 1,117 UNH students were selected for federal financial aid verification by the Department of Education. See the table below for a breakdown of the 2021-2022 financial aid verifications by type.

FAFSA Verification Group Type

# of Students Selected

V1 1,079 V4 31 V5 7

Total 1,117 UNH has an automated process that evaluates data received via feed from the Department of Education CPS system for students selected for verification. The process evaluates various data elements including, (1) verification type, (2) campus, (3) student type, and (4) if IRS data retrieval tool (DRT) used by the parent and student. Based upon these data elements, a tracking group is assigned to the student. Each tracking group has federal financial aid requirements that are assigned to the student record. These requirements can be tracked for each student in Banner Student Form RRAAREQ. These requirements must be satisfied for federal financial aid to be distributed to the student account. Banner Student has been configured to not allow for students to have financial aid posted to their student account unless UNH financial aid requirements are met. FAFSA Verification Reporting Institutions must report the verification results of identity and high school completion status for any student for whom (1) receives an ISIR with tracking flag V4 or V5 as selected by CPS and (2) request verification documentation using FAA Access to CPS. Institutions must report results no more than 60 days following the first request to the student for documentation of identity and high school completion. For students who receive a Pell Award, institutions must report the student’s verification status through the Common Origination and Disbursement System (COD) even if the student was not selected for verification.

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UNH FAFSA Verification Process Students and parents submit supporting documentation to UNH via NexGen Dynamic Form via the WebCat portal. Once online documents are submitted, Axiom is used to upload information from these documents into Banner Student, index the document in Xtender, and update the document requirement status in RRAAREQ. Axiom is a web-based matching and import tool. Once submitted, the UNH Financial Aid automated process compares values submitted on the supporting documentation to the FAFSA. If there is a mismatch on the verification worksheet, a DESLCT requirement is automatically put onto the student record in RRAAREQ via the Axiom process. Once all other required verification documentation is received the record will go into the Assistant Director Workflow for review and resolution. Tax information submitted via NexGen Dynamic Forms is reviewed by UNH Financial Aid staff to ensure that the return contains all required schedules and is signed. Once this is validated, Financial Aid staff selects the pages to import into Banner Student. Optical Character Reader (OCR) for AnyDoc works with Axiom to match information to Banner. OCR is the electronic or mechanical conversion of images typed, handwritten, or printed text into machine-encoded text, whether from a scanned document, a photo of a document, or a scene-photo. If the values are different, the system will update the student FAFSA to the information contained in the tax return. The updated value will be sent to the Department of Education as a correction to the Institutional Student Information Record (ISIR) via CPS system. Federal financial aid requirements stipulate that college financial aid offices should not process requests for professional judgement or disburse federal student aid until the verification process is complete. Financial aid administrators are required to ask for necessary documentation to complete verification. If the student or family refuses to supply this documentation, the college is prohibited from disbursing federal student aid to the student. According to 34 CFR 668.16(f), the institution should have an adequate system to identify and resolve conflicting information and discrepancies in the information that the institution receives from different sources with regards to a student’s application for financial aid under Title IV, HEA programs. To fulfill this requirement, an institution should obtain and review student aid applications, need analysis documents, tax return information, eligibility documentation and any other documentation that relates to a student’s eligibility for funds under the Title IV, HEA programs. FAFSA Updates and Corrections 34 CFR 668.55 states that financial aid administrators have the authority to, on the basis of adequate documentation, make adjustments to any or all of the following on a case-by-case basis: For an applicant with special circumstances under subsection (b) to the Cost Of Attendance (COA), the values of data used to calculate the Expected Family Contribution (EFC) or student aid index, or the values of data used to calculate the Federal Pell grant award. To account for special circumstances of a student, a Financial Aid Administrator (FAA) may choose to exercise Professional Judgement (PJ) to adjust a student’s cost of attendance or the data that determine a student’s EFC. PJ is the discretion grants to financial aid administrators by law to override the dependency status and/or make adjustments to need analysis, including data elements use to calculate the EFC and costs with the COA. The FAA decides if adjustments to standard components of need analysis are warranted due to special circumstances. An institution must submit a PJ change electronically, via FAA Access to CPS Online or third-party software. The reason for the adjustment must be documented and it must relate to the

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special circumstances that differentiate the student. An institution must resolve any inconsistent or conflicting information shown on the output document before making any adjustments. UNH has a Special Circumstances Form for families to communicate changes in their financial situation that has changed significantly from information provided on the FAFSA. These types of situations include changes in family structure: death, divorce/separation, unreimbursed medical/dental expenses, change of income due to loss of employment, and one-time adjustments to income. Families are required to submit supporting documentation to support these changes including signed federal tax return(s), letter of separation of severance benefit statement, last paystub or current profit and loss statement (if self-employed), unemployment benefit statement, and letter of explanation and other supporting documents to support appeal. The Special Circumstance Form is reviewed by the respective Financial Aid Administrator. Based upon this review and supporting documentation, the FAA makes any necessary adjustments to the student FAFSA data elements. Also, UNH processes corrections to student FAFSA data elements. These changes are submitted from UNH to CPS via a Banner job on a daily basis. The CPS processes the change, sends an ISIR to the University, and sends the student a Student Aid Report (SAR) acknowledgement. III. Scope

The audit focused on key controls surrounding the student financial aid data verification process. The main objective of the audit was to obtain reasonable assurance on adequacy and effectiveness of internal controls established to comply with the Department of Education’s verification requirements and to evaluate whether the risks associated are appropriately identified and managed. Specifically, we performed the following procedures:

• Selected a sample via risk-based stratification of records selected for verification by the Department of Education during 20-21 Financial Aid Award Period;

• Reviewed a sample of students selected for FAFSA verification for compliance with Department of Education requirements;

• Selected a sample via risk-based stratification of changes made to FAFSA data elements for the period September 2020 – August 2021;

• Reviewed a sample of students with changes to FAFSA data elements for authorization and supporting documentation;

• Reviewed a sample of students for satisfaction of financial aid verification requirements prior to disbursement of financial aid;

• Reviewed modify and view access to Banner Student Financial Aid Verification Form RRAAREQ, 2021/2022 Need Analysis Form RNANA22, 2021/2022 Need Analysis Document Verification Form RNAVR22, Applicant Comments Form RHACOMM, Requirements Tracking Group/Requirements Rules Form RRRGREQ, and Financial Aid Selection Rules RORRULE;

• Interviewed UNH personnel in the Financial Aid Office; • Met with UNH management to confirm results.

We came across data security elements during our audit work. These are presented in this audit report but were not the primary objective of the audit.

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IV. Report Structure The five observations in Section V of this report outline internal control issues for management’s attention and consideration. The order of the comments is based on their relative importance in terms of potential risk to UNH or foregone effectiveness if not addressed. The observations marked with an asterisk indicates the significance for management attention and resolution, which will be tracked for the USNH Audit Committee’s monitoring until resolved. The report contains recommendations that management has considered and incorporated the management action plans indicated below. The business process improvement observation in Section VI is strongly recommended but does not require a management action plan. V. Observations *1. Enhance compliance with Title IV federal financial aid requirements We noted that the Financial Aid Office is missing key financial aid policies and procedures in the areas of financial aid verification, professional judgment, special circumstance, FAFSA correction and update, and conflicting information to comply with Title IV federal financial aid requirements under 34 CFR Subpart E, 34 CFR 668.16, Section 479A of the Higher Education Act (HEA), and the Federal Student Aid Handbook. Also, there are no guidelines for financial aid administrators to verify FAFSA and special circumstances supporting documentation. Due to the lack of policies and procedures, we noted non-compliance with federal requirements in the following areas:

Issue # of Exceptions Lack of notification to students of verification selection and requirements

25 of 25

Non-compliance with Department of Education verification results reporting requirements.

7 of 7

Inadequate and missing verification supporting documentation. 2 of 25 Non-compliance with Department of Education requirement to report professional judgement adjustments processed by the University.

3 of 17

Inadequate and missing supporting documentation for special circumstances and corrections to FAFSA data.

7 of 25

Calculation errors for revised FAFSA data element values 2 of 25 There is the risk that student financial aid data verification is not managed to comply with Department of Education Title IV requirements, resulting in fines and penalties for the University. Refer to Appendix I for detailed observations and recommendations. We also noted that student and parent email correspondence to support corrections and updates to FAFSA data elements is copied and pasted as a student record comment in Banner Student Form RHACOMM. There is no retention of the email to support the correction or update made to the student FAFSA record. This condition exists because there are no financial aid supporting documentation protocols. There is the risk that UNH does not have original authentic documentation to validate and support changes made to the FAFSA, which could result in non-compliance with the financial aid requirements.

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We have the following recommendations with regards to this observation:

• Develop formal policies and procedures in the following financial aid areas, but not limited to:

o Financial aid verification o Verification reporting o Conflicting information o Professional judgement o Special circumstances o FAFSA corrections and updates

• Incorporate Federal Student Aid Verification and Professional Judgement Assessment Activities and Tools (available in Federal Student Aid Knowledge Center Library1) in the development of policies and procedures.

• Management should develop a financial aid desk manual for staff detailing financial aid data verification protocols.

• Management should report verification status for students selected for V4 and V5 verification and professional judgements adjustments to the Department of Education.

• Management should develop financial aid supporting documentation and retention protocols.

• Management should develop a process for the periodic review of verification document data for completeness and compliance with Department of Education requirements.

• Management should require the family to provide missing information on dependent verification worksheet and adjust or return excess financial aid, as appropriate.

• Management should monitor FAFSA corrections and updates on a periodic basis for compliance with UNH policies and procedures.

• Overrides and exceptions processed should be documented, reviewed, and approved. • Management should obtain missing or inadequate supporting documentation and adjust

financial aid awarded to students, as appropriate. • Management should correct calculation errors and adjust financial aid awarded to

students, as appropriate. • Training should be provided to financial aid staff on financial aid policies, procedures,

and protocols. • Refer to Appendix I for detailed recommendations related to student financial aid

verification and FAFSA data element change testing.

Management Action Plan Management understands the observations noted. During the audit process, management and the Financial Aid office staff started to develop and implement several of the recommended actions related to Appendix items 1,2,3, and 7. The recommendations associated with Appendix items 4,5,6,8,9, and 10 will be started in the next several months. All action items will be completed by July 1, 2022. These actions include the following:

• Management will create financial aid policies and procedures in the areas identified above and included in the Appendix. Specifically, in the following areas: financial aid verification and reporting including required elements defined by 34 CFR 668.53, processing of changes to verification documentation and FAFSA data and supporting

1 http://www.fsapartners.ed.gov/konwledge-center/resource-type/library/fsa%20assessments

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documentation requirements, use of professional judgement, and identification of conflicting information.

• Management will report V4 and V5 verification results and professional judgment adjustments, as required.

• Management will develop supporting documentation and retention protocols. • Management will develop a process for the periodic review of verification documentation. • Management will obtain missing information on the student’s dependent verification

worksheet and adjust aid, as appropriate. • Management will develop a process to periodically monitor FAFSA corrections and

updates. • Management will monitor and require approval for overrides and exceptions. • Management will obtain accurate or missing documentation, correct calculation errors,

and recalculate federal financial aid eligibility, after thorough review. Management will then take appropriate action based upon the risk associated with recalculated eligibility.

• Additional training will be provided to financial aid staff on policies, procedures, and protocols.

Responsible Party: Director of Financial Aid Due Date: July 1, 2022 *2. Enhance controls over system configurations We noted that controls could be enhanced over the testing and validation of the student financial aid verification system. Annually, UNH adjusts the Banner Student verification system SQL code and OCR for AnyDoc scripts to reflect changes in Department of Education verification requirements. Evidence to support testing and verification of the Banner Student SQL code and OCR scripts was not available. There is the risk that changes to the verification system do not meet Department of Education requirements. We also noted that controls over the configuration of the financial aid verification system could be enhanced. During audit testing, we noted one of the 25 selected students was not appropriately flagged by the Banner Student system process to complete verification requirements prior to distribution of federal financial aid to the account. According to federal requirements, a student must complete verification requirements to be eligible to receive federal financial aid. This occurred because undergraduate student records who were early admits for UNH Graduate School were improperly excluded from system evaluation of FAFSA information received by the Department of Education CPS system. The condition exists because the criteria used in configuration of the system is not documented and adjusted to reflect changes in financial aid processes. Additionally, we noted 13 of 21 selected students who received Pell awards were inappropriately reported as verified in the Department of Education Common Origination and Disbursement (COD) system. One student was reported as verified even though verification requirements were not satisfied. The remaining 12 students were reported as verified prior to the completion of verification of requirements. This occurred because the Banner Workflow was not modified to reflect the change in business process of allowing students financial aid to be packaged prior to the completion of verification. As a result, the Banner Workflow automatically populated a verification date based upon the completion of packaging requirements which was prior to the completion of verification requirements. There is the risk that students selected by

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the Department of Education for verification are not properly identified, tracked, reviewed, and reported to comply with federal requirements. Finally, we noted that financial aid staff modified a previously posted student record comment in RHACOMM (applicant comments form) after Internal Audit inquiry. Modify access to submitted student record comments posted in RHACOMM increases the risk that unauthorized or inappropriate changes could be made and the original audit trail is compromised. This condition exists because the system has not been designed to restrict modifications to student record comments. There is the risk that student record comments supporting documentation does not exist to support the financial aid process, which could result in non-compliance with Title IV requirements. We have the following recommendations with regards to this observation:

• Management should develop formal procedures for testing, review, and approval of system configuration changes Supporting documentation should be maintained for testing, review, and approvals.

• Management should modify the system configuration to align with current financial aid processes. Going forward, management should develop protocols for review and modification of configuration when making changes to financial aid processes, as appropriate.

• UNH should complete financial aid verification on the student that did not satisfy requirements and return any federal financial aid funds that student was not eligible for.

• Management should restrict edit access to RHACOMM. Changes or updates should be entered as a new student record comment.

Management Action Plan Management understands the observations noted. In response, the Financial Aid Office will complete the following actions:

• Management will update the current system testing plan documentation to include test plan details and supporting documentation of testing, review, and approval.

• UNH has completed verification on the student noted above and there were no changes to the student’s federal aid eligibility.

• Management is updating current system configurations to align with current processes. As financial aid processes evolve over time, management will continue to review and update system configurations.

• Management reviewed all other students to ensure this case was isolated and confirms that there were no other students in this situation aside from the one student noted in the audit. Management made system changes to prevent this situation in the future. Staff have monitored processing weekly throughout the spring semester and confirms that the revised system configuration is working properly.

• Edit access to RHACOMM is not a baseline student system item and cannot be modified by the Financial Aid office. However, management will update protocols with staff to require a new comment rather than editing existing notes. Further, management will put in place review protocols to periodically review comment creation and activity dates to ensure compliance with protocol.

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Responsible Party: Director of Financial Aid Due Date: October 1, 2022 3. Enhance security over login credentials During the audit, we noted an instance where a student worker used an employee’s Banner Student system login credentials to document a student phone call in Banner Student form RHACOMM. According to USY.VIII.B.4.4 Cybersecurity Acceptable Use Policy, “prohibited use includes use of another community member’s credentials, even if the community member gives their permission.” The employee sharing the credentials maintained highly sensitive and privileged access to the system. There is the risk that unauthorized use or modifications could be made to student financial aid records which could go undetected, resulting in the inaccurate calculation of financial aid eligibility. We have the following recommendations with regards to this observation:

• Staff should be trained on USNH Cybersecurity Acceptable Use policies. • Staff who are identified as sharing credentials should be formally notified of the policy

violation. Management Action Plan Management understands the observation noted. However, management disagrees with the representation presented in the observation. The actual occurrence was a student staff member, in full view of the Director of Financial Aid and with the Director of Financial Aid supervising the situation, notated a student telephone conversation when no other computer was available at the time. The student worker did not want to forget the conversation with the student and wanted to log the call immediately. The Director of Financial Aid allowed the student to note the conversation, while standing next to and supervising the student’s actions. At no point did the Director of Financial Aid provide login credentials to the student worker. Also, USNH Cybersecurity Acceptable Use policies are discussed annually with Financial Aid office staff. This practice will remain in place.

Responsible Party: Director of Financial Aid Due Date: Completed Internal Audit Response The student worker referenced in the above observation had been employed as a financial aid peer counselor from January 2018 until graduation in June 2021. The student worker had their own Banner Student credentials that had been used to denote conversations with other students and families. Because the employee provided a different recollection of the incident during the audit, there is the risk that sharing of credentials or access may have occurred on other occasions but not denoted in system. Because the employee has highly sensitive and privileged access to the system, the underlying risk is elevated.

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4. Enhance periodic access review and monitoring We noted that access to sensitive Banner Student forms is not appropriately restricted. Furthermore, a review of the appropriateness of user roles and access based upon job responsibilities is not performed on a periodic basis. Specifically, we noted that modify access to Banner Student Forms RNANA22 (student needs analysis) and RNAVR22 (need analysis document verification) was granted to two individuals in two UNH departments who do not have financial aid verification responsibilities. Also, we noted that modify access to Banner Student Form RHACOMM (applicant comments form) used by financial aid as an audit trail for student financial aid processing, correspondence, and phone calls was granted to seven users in six departments that do not have financial aid responsibilities. There is the risk that inappropriate users can enter or adjust student financial aid data or supporting information, resulting in inaccurate processing, and awarding of financial aid. In addition, we noted that 17 inappropriate users have view access to RNANA22 and RNAVR22. These Banner Student forms contain sensitive information including student and parent tax, income, and asset information, and student and parent SSN. Inappropriate access to the University’s sensitive data can result in loss of reputation to the University. We have the following recommendations with regards to this observation:

• Management should develop a formal process is established for the periodic review of Banner Student financial aid form access for appropriateness and alignment with job responsibilities.

• Remove inappropriate access or document justification for granted access. Management Action Plan

Management understands the observations noted. The periodic review of Banner Student Financial Aid form access was in process before this audit commenced. However, the action requires dependencies on USNH IT along with many other UNH offices. The recommended actions are already in process, although resolution is likely more than one year away because of the required dependencies. Work to be completed by December 31, 2023. In the interim, Financial Aid will review and remove inappropriate access or document justification of access by July 1, 2022. Responsible Party: Director of Financial Aid 5. Enhance data security of verification forms with sensitive information During our testing, we noted that students are required to enter student name, UNH ID, and social security number on financial aid verification forms. These forms are completed by students and parents via Dynamic Forms via the WebCat portal and uploaded into the student record in Xtender. The SSN is not required for proper routing and review of the verification forms. We noted that this is no redaction of restricted data prior to imaging in Xtender. Best practices are to avoid collecting personally identifiable information (PII) whenever possible, as

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there is the risk that restricted information could be compromised or exposed, resulting in financial and reputational loss for the University. We recommend management should modify financial aid verification forms to include least amount of personally identifiable information required for routing and review of documentation by Financial Aid and to comply with Department of Education requirements. Management Action Plan Management understands the observation noted. The student social security number was removed from the verification form and implemented for the 2022-23 financial aid year. Further, Financial Aid office staff have been formally trained on the redaction of personally identifiable information on financial aid supporting documentation. Responsible Party: Director of Financial Aid Due Date: Completed VI. Business Process Improvements 1. Enhance Banner Student financial aid verification requirement rules We noted that UNH has not configured the Banner Student verification requirement rules to consistently apply federal financial aid verification acceptable documentation requirements. For V1 and V5 verifications, UNH is required to validate student and parent (if a dependent student) income tax information. According to 34 CFR 68.57, an institution may accept, in lieu of an income tax return, the information reported for an item on the applicant’s FAFSA if the information has been obtained by the IRS and has not been changed. We noted that UNH configured Banner Student to not consider if the IRS data retrieval tool (DRT) was used to import the income tax information in the FAFSA for students flagged for V5 verification. As a result, the student and parent must separately upload their tax return or transcript via Dynamic Forms to satisfy the verification of tax information. Inconsistent application of requirements is inefficient and redundant as UNH must process duplicate information that has already been submitted by the student or family. We recommend that management modify the tracking groups and associated requirements to consistently apply federal financial aid acceptable documentation requirements as referenced in 34 CFR 668.57. Management Action Plan Management understands the observation noted. System configuration is unnecessary for the very small population impacted. Management has instituted policies and protocols that ensure only appropriate documentation is requested and reviewed as part of the verification process. Responsible Party: Director of Financial Aid Due Date: Completed

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# Title IV Category

Title IV Requirement Observation Risk Recommendation

1 Financial Aid Verification – Policies and Procedures (34 CFR 668.53(a))

According to 34 CFR 668.53 (a), the Department of Education stipulates that schools must have written policies about (1) the time period in which students must submit verification documentation, (2) the consequences for failing to submit those documents in time, (3) the method the University uses to notify students if their expected family contribution (EFC) and Title IV aid amounts change, (4) the procedures the University or students follow to correct the FAFSA data, and (5) the procedure the University follows to refer a student to the Office of Inspector General (OIG).

We noted that UNH does not have written financial aid verification policies and procedures to comply with 34 CFR 668.53(a).

There is the risk that the financial aid verification process is not managed to comply with Title IV requirements. Non-compliance could result in fines and penalties.

Management should develop financial aid verification policies and procedures, including but not limited to, elements required by 34 CFR 668.53.

2 Financial Aid Verification – Policies and Procedures – Notification (34 CFR 668.53(b))

An institution’s procedures must provide that it will furnish, in a timely manner, to each applicant whose FAFSA information is selected for verification a clear explanation of (1) the documentation needed to satisfy the verification requirements; and (2) the

We noted that UNH does not have a procedure to provide students selected for verification an explanation of their responsibilities, documents to submit, deadlines they must meet, and the consequences of failing to meet them to comply with 34 CFR 668.53(b).

There is the risk that the financial aid verification notification process does not meet federal financial aid results. Non-compliance could


Appendix I: UNH Financial Aid Verification and FAFSA Data Element Change Testing Observation Details and Recommendations

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# Title IV Category


applicant’s responsibilities with respect to the verification of FAFSA information, including the deadlines for completing any actions required under this subpart and the consequences for failing to complete any required action.

result in fines and penalties.

3 Financial Aid Verification – Policies and Procedures – COA/EFC Changes (34 CFR 668.53(c))

According 34 CFR 668.53 (c), an institution’s procedures must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under 479(a) of the HEA to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the EFC.

We noted that UNH does not have written financial aid verification policies and procedures to comply with 34 CFR 668.53(c).

There is the risk that UNH is not in compliance with federal financial aid requirements. Non-compliance could result in fines and penalties.


4 Financial Aid Verification - Reporting

According to the 21/22 Federal Student Aid Handbook, institutions must report the verification results for any student selected for V4 or V5 verification via the CPS system no more than 60 days following the first

We noted that UNH does not have verification status reporting procedures or supporting documentation for the verification reporting for the 38 student records from the 21/22 Federal Aid Year selected for V4 and V5

There is the risk that UNH is not in compliance with the federal financial aid verification reporting requirement.

Management should develop financial aid verification reporting policies and procedures. Management should develop protocols over the retention of


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# Title IV Category


request to the student for documentation.

verification by the Department of Education.

verification supporting documentation.

5 Financial Aid Verification - Documentation

According to the 21/22 Federal Student Aid Handbook, corrections and updates sent by a school must be based on reliable documentation in its possession that supports the changes to applicant data or signed documentation from the student or parent of a dependent student.

We noted one of 25 selected student records that did not have documentation to support the update of verification documentation submitted by the student or parent. Also, there was no written documentation to support the parent or student authorization of the change. We noted one other student did not have verification supporting documentation imaged in Xtender. Subsequently, UNH Financial Aid was able to provide verification supporting documentation.

There is a risk that the change to the verification documentation is invalid or unauthorized and the student was not eligible for the full amount of federal financial aid received. There is the risk that UNH is unable to support that verification documentation was verified to comply with Department of Education requirements.

Management should develop policies and procedures for the processing of changes to verification documentation and requirements to support the changes. Management should develop protocols over the retention of verification supporting documentation.

6 Financial Aid Verification – Supporting Documentation - Household Size/# in College

According to 34 CFR 668.57(c), an institution must obtain the name of each family member who is or will be attending a postsecondary educational institution at least half-time for award year, the age of each student, and the

We noted one of 12 students who submitted an incomplete dependent verification worksheet. This worksheet did not contain the name of the college that a sibling was attending. This condition existed because Axiom system

There is the risk that documentation submitted by a student or parent does not meet the federal financial aid acceptable

Management should develop a process for the periodic review of verification document data for completeness and compliance with Department of Education requirements.


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# Title IV Category


name of the institution that each student is or will be attending.

was not properly setup to reject invalid entries.

documentation requirements, resulting in non-compliance.

Management should require family to provide missing information on dependent verification worksheet and adjust or return federal financial aid, as appropriate.

7 Financial Aid – Special Circumstances

HEA Sec. 479A –Financial Aid Administrators have authority, on the basis of adequate documentation, to make adjustments on a case-by- case basis to the cost of attendance or the values of the data items required to calculate the expected student or parent contribution (or both) to allow for treatment of an individual eligible applicant with special circumstances.

We noted 7 out of 25 selected student records with exceptions: • Two student records with

FAFSA data element changes which did not agree with Special Circumstances supporting documentation provided by the student or parent of a dependent student.

• Two student records with a change in a FAFSA data element where the support for the calculation of the revised value was not documented and unable to be recalculated.

• One student record did not have documentation to support the override of the imputed asset calculation by UNH.

There is the risk that UNH is unable to support the FAFSA data element changes and that the change is inappropriate or unauthorized.

Management should develop policies and procedures for the processing of changes to FAFSA data and the documentation requirements to support the changes. Training should be provided to Financial Aid staff on financial aid policies, procedures, and protocols. On a periodic basis, management should monitor changes to FAFSA data elements processed by Financial Aid staff for appropriateness and compliance with UNH policies and procedures.


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# Title IV Category


• Two student records did not have a Special Circumstance Form to request adjustments to FAFSA data elements due to a change in their financial situation.

Overrides and exceptions processed should be documented, reviewed, and approved. Management should obtain missing or inadequate supporting documentation and adjust financial aid awarded to students, as appropriate.

8 Financial Aid – Corrections and Updates

According to the 21/22 Federal Aid Handbook, corrections or updates sent by a school must be based on reliable documentation in its possession that supports the changes to applicant data or signed documentation form the student or parent of a dependent student.

We noted two of 25 selected student records did not have supporting documentation for corrections made by UNH to the student’s FAFSA data elements.

There is the risk that UNH is unable to support the FAFSA data element changes or that the change is inappropriate or unauthorized.

Management should develop policies and procedures for the processing of changes to FAFSA data and the documentation requirements to support the changes. On a periodic basis, management should monitor changes to FAFSA data elements processed by UNH for appropriateness and compliance with UNH policies and procedures.

9 Financial Aid – Professional Judgement

According to the 21/22 Federal Aid Handbook, if an institution makes a

We noted three of 17 professional judgement adjustments were not properly

There is the risk that UNH is not in compliance with

Management should develop procedures for the use of professional


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# Title IV Category


professional judgement adjustment, the institution must set the FAA Adjustment flag in FAA Access to CPS Online or via the Electronic Data Exchange (EDE).

flagged when submitted in CPS Online System.

federal financial aid requirements and a professional judgement is made without accurate information.

judgment and processing PJ adjustments to FAFSA data.

10 Financial Aid – Conflicting Information

According to 34 CFR 668.54(a), if an institution has reason to believe that an applicant’s FAFSA information is inaccurate, it must verify the accuracy of that information.

We noted that UNH does not have procedures in place to identify conflicting information and select a student for verification.

There is the risk that a student submits inaccurate information on the FAFSA that goes undetected and results in inaccurate awarding of federal financial aid.

Management should develop procedures to identify conflicting information and require verification of select FAFSA data elements.


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Athletics Cash Carrying & Depositing Audit Report

Report issued June 10, 2022

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June 10, 2022 James W. Dean Jr., President University of New Hampshire Durham, New Hampshire 03824

Dear President Dean: This letter conveys our report on the audit on the University of New Hampshire Athletics Cash Carrying & Depositing. As communicated in our engagement letter of November 29, 2021, the primary objective of the audit is to obtain reasonable assurance on the effectiveness on internal controls over athletics cash carrying and depositing and whether existent internal controls are efficient, effective, and operating as expected. This report reflects our observations, which were discussed with members of UNH management, and their action plans in response to our recommendations. It is being distributed to the individuals listed below and will be presented to members of the Audit Committee of the University System of New Hampshire (USNH) at its next scheduled meeting. It is also available for review by external auditors of USNH. We appreciated the full cooperation and assistance we received from Thomas Greer, Assistant Athletic Director for Business Operations/Finance and Cullen Barnes, Director of Ticket Sales & Operations with whom Christine Heise, Senior Internal Auditor, worked most closely as she conducted the fieldwork for this audit. Please feel free to contact me with any comments, questions, or suggestions you may have. Sincerely,

Ashish Jain Director of Internal Audit

Distribution: Karen Benincasa, Assistant Vice Chancellor, Financial Affairs, USNH Brad Brown, Deputy Director of Athletics, UNH Francine Ndayisaba, Director Controller & Financial Operations Center, USNH Catherine Provencher, Chief Administrative Officer and Vice Chancellor for Financial Affairs and Treasurer, USNH Marty Scarano, Director of Athletics, UNH Marcel Vernon, Chief Financial Officer, UNH

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University of New Hampshire Athletics Cash Carrying & Depositing Audit

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I. Executive Summary We performed an audit of the University of New Hampshire Athletics cash carrying & depositing operations. We noted lack of policies and protocols to ensure the completeness and accuracy of Athletics revenues and collections. Key reconciliations are not being completed to verify and confirm the accuracy of the financial activity. Athletics revenues related to game guarantees, season ticket sales, and facility rentals are not recorded in accordance with USNH policies and procedures. There is the risk that UNH may not be able to collect revenues appropriately and that the financial statements may not properly reflect the financial condition of the University. We recommend that management should revise the Athletics control structure to align with expectations and clarify roles and responsibilities over cash and revenue operations. Management should also enhance the configuration of the athletics ticketing system (Audience View) to enhance controls and to efficiently manage ticket transaction processing. Management should provide training to staff responsible for the processing, recording, and review of Athletics financial activity. We also noted that protocols can be enhanced to ensure ethical integrity and proper accounting of Athletics financial activities. During our testing, we noted a receipt of ticket sales that was improperly recorded. The resulting missing funds could not be identified due to inadequate reconciliation procedures. We also noted cash deposit tickets that were modified without appropriate approval. We came across a scheme to provide special access to Athletics sporting events, while the receipts from granting special access were not recorded and accounted for in the financial records. We recommend that management should follow-up and resolve related discrepancies. We noted that Athletics should develop cash handling, depositing, and change policies and procedures, while considering segregation of duties. Management should review technologies available to reduce or eliminate cash collected in athletics ticketing, fundraising, parking, and other areas. Management should evaluate and reduce the change funds. In addition, we noted that Athletics should develop procedures for processing of credit card transactions and handling related data to comply with PCI-DSS requirements and USNH policies. We noted shared login credentials for processing credit card transactions in PayConex. Finally, we recommend that management enhance 50/50 raffle policies and procedures and configure the software application to have systematic controls in place, including the use of beginning/ending ticket number to ensure revenue completeness. II. Background UNH Athletics accepts cash and cash equivalents in various business processes, including (1) ticket box office operations, (2) football parking, (3) fueling station, (4) athletic contracts, (5) 50/50 raffles, (6) athletic team golf tournaments and events, (7) team fundraising, (8) summer youth athletic camps, (9) summer camp concessions, and (10) team apparel sales. UNH Athletics Box Office UNH Athletics operates their primary Box Office at the Whittemore Center on Monday – Friday from 10:00 am to 5:00 pm. The Box Office opens for additional hours on gameday weekends and evenings. Athletics operates the Wildcat Stadium Box Office and Field House Box Office

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only on game days. On football game days, the Wildcat Stadium Box Office opens four hours prior to opening kickoff and on hockey game days, the Whittemore Center Box Office opens two hours prior to opening faceoff. In August 2021, Athletics implemented a new ticketing software, Audience View, to process all athletic sporting event ticket transactions. Audience View facilitates all season and individual ticket transactions purchased online and at the Box Office. As of December 15, 2021, FY22 ticket sales was approximately $1.42 million, of which cash represented 2% of total ticket sales. FY22 athletic parking sales was approximately $102,150, of which cash represented 11% of total parking sales.

Ticket transactions processed as other payment type includes complimentary tickets issued to home and visiting team athletes and coaches, internal transfers for UNH departments, and outside group billed tickets. Season Ticket Packages UNH Football and Men’s Hockey offer season ticket packages for purchase. These ticket packages are secured with a $25 deposit per package. The remaining ticket package balance is due to UNH by July 1. The Box Office prints game tickets and mails them to season ticket holders in mid-July. Football Game Parking Football game spectators purchase a parking voucher to park in the Boulder Lot or Lot A. The voucher costs $20 and can be purchased in advance online or a parking fee can be paid in cash at the parking lot on game day. staff mail the pre-purchased parking voucher to the customer. For advanced purchases, spectators present their pre-purchased parking voucher at the Lot for entry. At the end of the game, cash received for parking is brought to the Whittemore Center Box Office for counting and entry into Audience View. The cash proceeds and Audience View reconciliation report is then dropped off in the Field House drop box for deposit. Athletic Contracts UNH Athletics enters into various revenue contracts including game guarantees, facility rentals, apparel revenue share, and concession revenue share. Contracts are generated and managed

Cash, 2%Check,

2%

Credit Cards, 55%

Old System -Checks/Credit Cards, 36%

Other , 5%

FY22 Athletic Box Office Ticket Sales by Payment Type

Cash, 11%

Credit Cards, 87%

Other , 2%

FY22 Athletic Parking Sales by Payment Type

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by the Senior Associate Athletic Director, Internal Operations. Contract payments are received by various Athletics staff and dropped off in the Field House drop box or with the Assistant Athletic Director for Business Operations/Finance. Fueling Station The Wildcat Fueling Station runs out the Field House and helps student athletes receive the proper nutrition from quick and easy snack options. Athletes receive one free item every day; additional items are available for sale to athletes and UNH Athletics staff. Sales are processed through the Red Card Athletics POS system. Sales are reconciled on weekly basis and proceeds are place in the Field House drop box for deposit. Summer Youth Athletic Camps UNH Athletics runs various summer youth athletic camps on the UNH campus. These camps offer commuter and overnight experiences for youth athletes. Campers register on-line through Destiny One where registration payment is submitted. Athletics Fundraising Athletics teams participate in fundraising activities to help fund team activities, travel, meals, equipment, and miscellaneous team expenses. The types of fundraising activities include 50/50 raffles, ski/skate sale, golf tournaments, raffles, apparel sales, meet the team experiences, summer camp concessions, youth clinics, and other miscellaneous fundraising events. UNH Athletics fundraising sales for the time period of July 1, 2022 – December 15, 2022, were approximately $330,290, of which cash represented 23% of total fundraising revenue.

* - Based on ski skate sale summary analysis provided by Athletics. 50/50 Raffle UNH Athletics runs the 50/50 raffle at all UNH Football and Men’s Hockey games. UNH uses the AscendFS software application to run the 50/50 raffle. Athletics has six mobile units that team athletes use to sell tickets during the game. Men’s Hockey 50/50 is run by the cheerleading or gymnastics team. Net fundraising proceeds are split equally between the Men’s Hockey team and either the UNH Gymnastics or Cheerleading team (dependent on what team runs the raffle). Football 50/50 raffle is run by the UNH Ski team, and all of the net proceeds are

50/50 RaffleCheerleading TailgatingFundraiser

GolfTournament

Raffles

GolfTournamentSponsorship

s

GolfTournamentRegistration

Fees

Apparelsales Youth clinics Meet the

TeamSki Skate

Sale *

Credit Cards - - 325 1,500 18,550 - - - 164,106

Check - - - 23,465 21,370 1,045 9,870 203 14,105

Cash 39,219 9,389 3,480 - 2,800 3,340 - 1,568 15,958

0%10%20%30%40%50%60%70%80%90%

100%

FY22 Athletics Fundraising by Type and Payment Method

Cash Check Credit Cards

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allocated to the ski team. The 50/50 raffle is cash only. Teams running the 50/50 raffle receive a cash setup of $100 from the Whittemore Box Office change fund. These funds are split amongst the various team members to make change in the sale of 50/50 tickets. The AscendFS application tracks the total 50/50 pot. Upon the closing of the 50/50 raffle, the collected cash is brought to the Box Office to be counted and compared to the AscendFS report. The winning number is randomly selected via AscendFS. The winner presents the winning ticket and completes the UNH 50/50 Winner Verification Form and the W-2G tax form. Form W2-G requires an organization to obtain the winner’s name, address, and SSN and verify this information through the review of two forms of identification. Upon receipt of W-2G tax documentation, USNH Accounts Payable issues a check to the winner. Golf Tournaments and Events Golf tournaments and events are held by the various UNH athletic teams for fundraising to help fund team expenses. In addition, Athletics collects registration fees from individuals to participate in the event or golf tournament. Advance registration payments are processed in IModules (Ellucian Advancement product). Registrations on the day of the event are handled by the staff member running registration table. Cash, credit cards, or checks are accepted as forms of payment. Also, raffles are held at the golf tournaments and events to raise funds for the team. In addition, Athletics receives corporate sponsorships for these events. Cash and check payments received by the Director of Summer Programs and Events are summarized on the UNH Deposit Slip and placed in the Field House drop box for processing. Team Apparel Sales UNH Athletic teams sells team apparel at select athletic contests or summer camp programs. Cash, checks, and credit cards are accepted as payment methods. Summer Camp Concessions UNH Athletic teams will run concession stands to sell snacks and drinks to campers. Snacks and drinks are purchased by the team on a coaches’ purchasing card and marked up for sale to campers. Cash is received for snacks and drinks by campers. Box Office Cash Handling A cash drawer is setup at the beginning of the day at the Whittemore Center Box Office. All other Box Office windows accept only credit card payments. At the end of the day, a reconciliation report is run from Audience View. Two Box Office staff count the cash drawer and agree the closing funds to the report. If there is a variance, the staff will review detail transaction activity to try to identify the reason for the variance. Adjustments will be made in Audience View if an error is detected. If the staff is unable to resolve the variance, the amount of the discrepancy will be noted on the reconciliation report. The staff will separate the cash drawer startup funds and sales proceeds and summarize the activity based upon sport. The ticket sales proceeds are placed in a manila envelope in the Field House drop box. The Box Office change fund also provides cash setups for other Athletics activities (i.e., Box Office operations at the football stadium and Field House), football parking operations, and team fundraising events. Cash setups are returned at the end of the event to the Whittemore Center Box Office. Deposit Process Cash and checks for deposit and supporting documentation is placed in an envelope in the Field House drop box. The Assistant Athletic Director (AD) for Business Operations/Finance picks up deposits from the drop box on a periodic basis. The deposits are brought up to the office of the

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Assistant AD for Business Operations/Finance for processing. The cash and checks are counted and compared to supporting documentation. The Assistant AD will complete the UNH Deposit Slip, if not already completed by the depositor, and then signs off on the deposit slip and/or supporting documentation to indicate that the verification of cash/checks received occurred. If there is a variance between the cash/checks and supporting documentation, the Assistant AD will contact the person responsible for the Athletics areas to resolve. The Assistant AD completes the bank deposit ticket and walks the deposit to People’s United Bank. The bank issues a bank deposit slip as confirmation that the cash receipt was processed. Upon return from the bank, the Assistant AD completes the FUPLOAD (which denotes the FOAPAL) for each transaction included in the bank deposit. Then the FUPLOAD, bank deposit slip, UNH deposit slip, bank deposit ticket, and copies of checks and supporting documentation is imaged and emailed to the FOC. The FOC uploads the FUPLOAD for posting into Banner Finance. Starting in January 2022, the deposit of cash and checks was transitioned to the UNH Cashier’s Office. For cash deposits, Athletics completes the USNH Cash Deposit form and encloses the cash in the USNH tamper-proof bank deposit bag. For deposits greater than $1,000, the Assistant AD coordinates with the USNH FOC Non-Student Accounts Receivable Office (NSAR), the deposit pickup; whereas deposits less than $1,000 are walked over to the UNH Cashier’s Office at Stoke Hall. The FOC NSAR Department will deposit the cash and send an email to Athletics with the corresponding journal document number. For check deposits, Athletics endorses the checks and completes the USNH Check Deposit form. Athletics delivers the checks and a copy of the USNH Deposit form to the USNH NSAR Office. The FOC NSAR Department will deposit the check(s) and send an email to Athletics with the corresponding journal document number. Reconciliation Process USNH Accounting Services is responsible for reconciling cash receipts posted in Banner Finance to the respective bank statement. At the end of the month, Accounting Services staff runs monthly activity from Banner Finance for Fund: BANK and Account Number: 110211 (for cash/checks activity) and Fund: BANK and Account Number: 110216 (for credit card activity). This information is compared to the bank statement and a reconciliation is prepared to balance the bank statement and Banner Finance cash balance. If there are any variances, USNH Accounting Staff will work with the respective department to get additional information and make adjustments, as necessary. These reconciliations are prepared monthly by the USNH Accounting Specialist and reviewed by the USNH Senior Accountant. Athletics Change Funds and Petty Cash USNH Policy 04-003 Change Funds outlines requirements on establishing and maintaining a departmental change fund. Each change fund is the responsibility of the head of the department or activity receiving the fund. The Custodian is responsible to the Department Head for proper safekeeping of the change fund and to ensure that all policies and procedures are adhered to. Change funds should be established at an amount which is not in excess of the amount required for efficient daily cash sales operations, normally not to exceed $300. Change funds must be returned or reduced when the need no longer exists or diminishes. Otherwise, the amount of a change fund remains constant. Unlike a petty cash fund, a change fund does not require periodic replenishment.

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USNH Policy 04-001 Petty Cash Funds outlines procedures for establishing and maintaining a departmental petty cash fund. The department head designates one individual as the Custodian who is accountable for the custody of the funds. Also, the policy states that if the physical location of or the original purpose of the petty cash fund should change, the Custodian should submit a new Cash Fund Request to the USNH Controller’s Office for approval. Petty cash may be used to reimburse authorized expenditures up to $200 per transaction for local retail purchases, meeting expenses, business meals, local transportation etc. Petty cash funds require monthly reconciliation and monthly replenishment if un-replenished receipts exceed $300. UNH Athletics maintains two change banks and one parking petty cash fund, comprised of the Whittemore Box Office change fund ($8,000), Fueling Station change fund ($20), and Athletics parking petty cash ($50). The Whittemore Box Office change fund is used to provide cash drawer startup funds for Box Office operations, Field House ticket office operations, and Athletics fundraising activities. The Fueling Station Change Fund is used to provide cash drawer startup funds for Fueling Station operations at the Field House, which provides nutritious snacks to student athletes and teams. The Athletics Parking Petty Cash fund is used for guests of Athletics that park in the metered spots in front of the Fieldhouse. UNH Athletics also maintains a safe in the Assistant Athletic Director for Business Operations/Finance’s office. This safe is used to store cash and checks prior to deposit or pickup by the UNH Cashier’s Office. USNH Financial Services Policies and Procedures – Cash Receipts, Revenue, and Adequate Supporting Documentation USNH Financial Services Policy 10-001.B defines operating and non-operating revenues and addresses recording receipts as credits to expense. Under the detailed procedures, this policy states, “Revenue is always recorded at the gross amount, not net of any discounts.” USNH Financial Services Policy 10-002.B outlines who has the authority to make sales on credit, what rules must be followed, and the responsibility for reconciliations and proper accounting in Banner. Departments with CFO approval to make credit sales must follow policies and procedures of the campus Credit and Collections department relative to extension of credit, invoice and statement generation and frequency, aging analysis, delinquent account follow-up, and write-off of non-collectible accounts. Under the detailed procedures for 10-002, the policy states that “Revenue should be recorded when an exchange has taken place and the earning process is complete. An exchange has taken place when services for the buyer have been fully performed. The earnings process is complete when (a) all necessary costs to produce the revenue have been incurred and recorded and (b) collection of the sales price is reasonably assured by receipt of money or by a promise to pay money at a future date. The collection of the sales price is generally considered to reasonably assured when an invoice is sent to a customer or when cash is received from a customer, whichever comes first.” USNH Financial Services Policy 10-004 Receipt and Deposit of Cash Items outlines procedures for proper receipt and depositing of currency, checks, bank card charges, and other cash equivalents. This policy covers the timeliness of cash deposits and the responsibility for safeguarding the receipt of cash items. The requirements of this policy include that checks and currency totaling $800 or more must be deposited within 48 hours of receipt and at the

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departmental ash collection locations, the dean, director, or department head is responsible for safeguarding cash items by employing appropriate internal controls. USNH Financial Services Policy 02-210 Adequate Supporting Documentation explains the requirements for and purposes of keeping supporting documentation for USNH accounting transactions. Guidelines and examples of adequate supporting documentation for cash receipts includes (1) copy of deposit slip, (2) daily cash log/bath posting sheet and copies of receipts given, (3) daily ledger from cash register(s) showing receipts collected for the day, or cash register tape(s) if daily ledger sheet is not available, (4) support for application of receipt(s) to outstanding receivables such as: check stubs with notations of USNH invoice numbers or customer correspondence included with receipts, (5) if the individual receipt is being recorded as a reduction of a prior expenditure, a written explanation should be included on check stub, and (6) copies of checks if receipt is over $50,000 or significant to the individual transaction. Financial and Administrative Restructure (FAR) Project The FAR Project consolidated the financial services activities and redesigned related jobs and organizational structures through USNH and individual campuses. The FAR Project consolidated financial services activities including general accounting, accounts payable, treasury operations, budgeting and financial planning, payroll, and research finance activity throughout the System. As part of this restructure, campus BSC’s were eliminated in late fiscal year 2021 and the responsibility for day-to-day financial operations was transitioned to the departments. Prior to the restructure, UNH Athletics relied on the Central Administration BSC to provide financial and accounting support. Athletics is now responsible for day-to-day financial and cash operations. Starting in January 2022 the UNH Cashier’s Office works with departments to facilitate the deposit and recording of cash and check activity. III. Scope

The audit focused on key controls surrounding the cash collection, carrying, and depositing processes within UNH Athletics. The main objective of the audit to obtain reasonable assurance whether the risks associated with athletics cash carrying and depositing are appropriately identified, and managed, internal controls are in place, and the established internal controls are designed effectively and operating as expected. Specifically, we performed the following procedures:

• Performed walkthroughs for UNH Athletics cash areas, including Ticket Box Office Operations, Athletics Youth Summer Camps, Fueling Station, Sporting Event Parking, Golf Tournament Fundraisers, 50/50 Raffle, Miscellaneous Team Fundraising, and Athletics Contracts;

• Reviewed a sample of UNH Athletics cash receipts for compliance with USNH and UNH policies and procedures, segregation of duties, adequate supporting documentation, and deposit reconciliation to support the receipt, deposit, and recording of transaction in Banner Finance;

• Performed data analytics on Audience View ticket transactions from August 12, 2021, to December 15, 2021;

• Reviewed a sample of UNH Athletics team meal money cash transactions for compliance with USNH and UNH policies and procedures;

• Performed an unannounced cash handling observation at Whittemore Center Box Office;

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• Performed a cash handling observation at a UNH Men’s hockey game; • Reviewed cash deposit box and safe management protocols; • Interviewed personnel in UNH Athletics, UNH Finance, and USNH Accounting Services

and met with UNH management to confirm results • New USNH Revenue and Cash Receipts policies 10-005 and 10-006 were applicable

starting March 11, 2022. Also, policy 10-004 was updated on March 11, 2022. As these new and updated procedures were not available at the time of audit fieldwork, we did not evaluate compliance with the new and updated policies.

We came across revenue completeness and recognition as well as data security issues during our audit work. These are presented in this audit report but were not the primary objective of the audit. Internal Audit also provided management a detailed issue list containing support of our observations. Due to lack of control structure, Internal Audit does not provide any assurance over any aspect of the Athletics cash or revenue operations. IV. Report Structure The seven observations in Section V of this report outline internal control issues for management’s attention and consideration. The order of the comments is based on their relative importance in terms of potential risk to UNH or foregone effectiveness if not addressed. The observations marked with an asterisk indicates the significance for management attention and resolution, which will be tracked for the USNH Audit Committee’s monitoring until resolved. The report contains recommendations that management has considered and incorporated the management action plans indicated below. The business process improvement observation in Section VI is strongly recommended but does not require a management action plan. V. Observations *1. Ensure appropriate recording of Athletics revenues There are inadequate policies, procedures, and protocols over ensuring completeness and accuracy of revenues generated from ticketing sales, team fundraising, 50/50 raffles, football parking, athletic contracts, fueling station sales, golf tournament and events, summer programs, summer concessions, and team apparel sales. POS reports and receipts are not generated consistently to support the completeness of these revenue streams. Furthermore, accounts receivables related to season ticket sales, game guarantee contracts, and facility rentals are not properly recorded and reconciled in a timely manner, as required by USNH Financial Services Policy 10-002 Billing for Goods Sold or Services Rendered. We also noted that fundraising revenue is not being properly recorded at the gross amount to comply with USNH Financial Services Policy 10-001. The ski/skate sale revenues and expenses are inappropriately accumulated in an Athletics general clearing liability account and the net revenue is journaled to the revenue account in the Friends of Skiing gift fund. Therefore, there is a risk that UNH may not be able to collect revenues appropriately and that the financial statements may not properly reflect the financial conditions of the University. This was mainly due to lack of the structure and authority over Athletics finance operations and the lack of clarity of roles and responsibilities among Athletics staff. Therefore, the accuracy, completeness, and validity of revenue transactions cannot be consistently ensured.

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We also noted the following: a. For a selected season ticket holder, the balance due of $2,526 was not identified because

the ticket order for $5,526 was inaccurately recorded as a no payment transaction. This occurred because there is no review and approval of no-payment, refunded, or voided ticket transactions. Also, for this ticket holder, we noted that a credit card payment of $3,000 was not processed in Audience View. These conditions exist because Audience View (ticketing system) is not properly configured to accept credit card transactions directly through the software application. Instead, Box Office staff processes the credit card ticket transaction in PayConex (credit card processing merchant gateway) and then manually enter the credit card payment amount in Audience View. There is the risk that the ticketing revenues are not accurate or complete, resulting in financial loss for the University.

b. We noted that season ticket sales are recorded on the cash basis. Season tickets are

printed and mailed to season ticket holders in early July, at which time the revenue should be accrued as the exchange has taken place and the earning process is complete. We noted a lack of formal protocols for the identification, billing, tracking, and collection of payments due for season ticket holders and ticket packages. We noted that Athletics has a manual spreadsheet to track season ticket package orders, deposits, and payments, but the spreadsheet is not consistently maintained to provide a current ticket accounts receivable balance. There are no protocols for the identification, tracking, monitoring, and follow-up on tickets accounts receivable balances. We also noted payments in Audience View that were not reflected on the spreadsheet. As a result, we were unable to validate the accounts receivable balance in the spreadsheet. There is the risk that the ticketing revenues are not accurate or complete.

c. Based on data analytics on ticket transactions, we noted the following:

i. 24 transactions totaling $41,369 in UNH department internal payment transfers that were not processed and recorded in Banner Finance

ii. 3 transactions totaling $2,390 in anonymous customer transactions inaccurately processed as internal payment transfers in Audience View

iii. 9 transactions totaling $1,176 in staff and team complimentary tickets inaccurately processed as internal payment transfers in Audience View

iv. 32 complimentary ticket transactions assigned receipts totaling $17,891 v. 171 void and refund ticket transactions totaling $35,165 were not approved or

authorized vi. 743 non-student complimentary ticket transactions processed by ticketing staff and

no documentation on authorization and appropriateness was maintained. These conditions exist because Audience View has not been configured to restrict access and require approval for internal payment transfer, no payment, void, and refund ticket transactions. In addition, there are inadequate training and protocols for the handling of ticketing transactions, including complimentary tickets and internal transfers. There is the risk that ticket revenues are not accurate or complete. We have the following recommendations with regards to this observation: • Management should evaluate structure, authority, and responsibilities of Athletics

department for alignment with expectations. Management should consider Visio diagrams of Athletics revenue cycles provided by Internal Audit in this evaluation process.

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• Management should formalize the documentation of roles and responsibilities for UNH Athletics areas.

• Reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions.

• Management should develop a formal receipting process for manual cash receipts. • Management should develop a Box Office desk manual. • Training should be provided to staff responsible for processing, recording, and reviewing

Athletics revenue transactions. • Management should review a game summary for reasonableness; the number of tickets

sold corresponds with expected revenue. • Management should perform after game reconciliations to review ticket sales and the

reasonableness of ticketing revenues. • Develop protocols for season ticket orders, billing, and distribution, considering the

requirement that balances must be paid in full prior to mailing or activating tickets. • Leverage USNH FOC-Non-Student AR for assistance in managing season ticket and

facility rentals billing and collections. • Develop protocols for the identification, tracking, monitoring, and follow-up on outstanding

tickets accounts receivable. • Management should work with Audience View to develop a system generated ticket

accounts receivable report. • Management should follow-up with customers who have an outstanding ticket balance due. • Management should develop protocols to manage credit card chargebacks. • Management should develop user roles in Audience View to customize and restrict access. • Management should review and correct ticket transaction entry errors in Audience View. • Management should develop processes and procedures related to complimentary tickets

and internal ticket transfers. • Management should develop protocols to verify revenue completeness of each revenue

stream, for example, comparing sale of parking tickets to vehicles parked/parking tickets scanned.

• Management should coordinate with USNH FOC-Accounting Services to record internal payment ticket transfers in Banner Finance and adjust ski/skate sale fundraising activity to properly record gross fundraising revenue and expenses in the Friends of Skiing fund.

• Management should evaluate and adjust the configuration of Audience View to meet UNH Box Office needs and increase controls over ticket transaction processing.

• Management should integrate Audience View with the PayConex merchant gateway. Management Action Plan The following actions will be undertaken to address the above observation: • Management will evaluate organizational and staffing structure for effective and efficient

processing of Athletics revenue, while considering segregation of duties. As part of this process, management will formalize and document roles and responsibilities. Work to be completed by December 1, 2022.

• Management will review and create an inventory of Athletic cash sales and fundraising activities by July 1, 2022.

• Management will develop Athletics departmental policies and procedures, which will be communicated to constituents. Work to be completed by December 1, 2022.

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• Management will develop a Box Office desk manual by July 1, 2022. Season ticket protocols and ticket transaction processing and adjustments will be incorporated into this manual.

• Training will be provided to staff on Athletics policies and procedures and Box Office operations. Also, Athletics staff will participate in University-wide training opportunities and coordinate with UNH Finance for training and guidance on USNH and campus revenue policies and procedures. Work to be completed by December 1, 2022.

• Management will reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions. Work to be completed by December 1, 2022.

• Management will develop a formal receipting process for manual cash receipts, while looking to reduce cash transactions and leveraging credit card options. Work to be completed by December 1, 2022.

• Management will develop processes and procedures related to complimentary tickets and internal ticket transfers by July 1, 2022.

• Management will work with Audience View and USNH Treasury to integrate Audience View and Pay Conex. Work to be completed by September 1, 2022.

• Management will develop a process for the review of game revenues for reasonableness, incorporating presales, gameday sales, and scan counts to be completed by September 1, 2022.

• Athletics is moving towards self-service and mobile ticket functionality. As part of this initiative, season tickets will not be active until payment has been made in full. As a result, there will be no season tickets accounts receivable. Work to be completed by September 1, 2022.

• Management will follow-up with customers who have an outstanding season ticket accounts receivable balance due and determine appropriate action by September 1, 2022.

• Management will review credit card chargebacks as part of the monthly review and allocation of Athletics credit card activity. Work to be completed by September 1, 2022.

• Management will work with Audience View staff to configure application with user roles, integrate credit card processing, and ticket reporting to be completed by September 1, 2022.

• Management will review and correct ticket transaction entry errors in Audience View by July 1, 2022.

• Athletics will evaluate opportunities to minimize manual cash activities and leverage technology and credit card options. Work to be completed by December 1, 2022.

• Athletics management worked with UNH Central Finance to record all FY22 ticket transaction internal payment transfers. Going forward, Athletics Box Office staff will send internal transfer documentation to UNH Finance upon receipt for processing.

• Athletics management will coordinate with USNH FOC-Non-Student AR to review facility rental activity and billing procedures.

• Management will coordinate with USNH FOC-Accounting Services to adjust ski/skate sale fundraising activity to properly record gross fundraising revenue and expenses in the Friends of Skiing fund. Work to be completed by July 1, 2022.

Responsible Party: Deputy Athletic Director, Assistant Athletic Director, Business Operations/Finance, and Associate Athletic Director, Business Development Due Date: Various – see due dates referenced above Internal Audit Response The absence of a process to review manual cash receipts for reasonableness increases the risk that funds are misappropriated. The risk can be mitigated by reducing cash operations, but

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residual risk still exists until all cash is eliminated. The acceptance of risk until cash is reduced or eliminated should be evaluated and signed off by the CFO. *2. Enhance procedures to ensure compliance with USNH Fraud policy We noted that there are inadequate protocols to ensure ethical integrity and proper accounting of Athletics activity. According to USNH BOT.III.K Fraud, “Every person working on behalf of USNH – including faculty, staff, student employees, and volunteers has the basic responsibility to safeguard and preserve the assets and resources of USNH and its component institutions and to conduct work duties in an ethical and professional manner. . . No intentionally false or artificial entries shall be made in an official USNH record or documentation. . .” Based upon our ticket transaction testing and cash handling observation, we noted ticket transaction payments that were intentionally improperly recorded. Specifically, we noted that a selected transaction had a $4,000 check payment variance. The Audience View report showed $19,835 in payments; in comparison to the $15,835 in check payments received and processed for deposit by the Box Office staff. This variance was not recorded in Banner Finance and there was no follow-up or review by Box Office staff. Upon inquiry by Internal Audit, the staff did additional research and determined that the $4,000 check payment was incorrectly coded as a check payment and should have been recorded as a credit card in Audience View. The ticket transaction was modified in Audience View to a credit card payment type. Internal Audit requested credit card receipt documentation from PayConex to support the credit card payment. We noted that there was no record of the credit card payment in PayConex. The transaction was modified although there was no credit card payment for this ticket transaction, which is non-compliance with BOT.III.K.1.3.5. Additionally, UNH Athletics does not have reconciliation procedures in place, improper entries can go undetected. There is the risk that UNH did not receive all funds related to ticket transaction activity, resulting in financial loss for the University. During surprise cash count, Internal Audit was informed that there was a $25 cash payment in a cash drawer that had not been processed. This payment represented an upgrade for a season ticket holder for special access at a UNH football game. This season ticket holder had requested special access for previous football games during the season. The Director was unsure on how to process this payment or how these payments were processed in the past, as this access was not an upgrade available for sale and consequentially not setup in Audience View. There is the risk that special access arrangements do not best represent UNH interests and associated payments are misappropriated, misplaced, or lost. Finally, we noted two selected bank deposit transactions that had a deposit ticket that was modified without appropriate reason assigned and independent review. These discrepancies are not identified in a timely manner because there are inadequate protocols to identify and follow-up similar inappropriate and unauthorized changes. There is the risk that cash funds were misappropriated, lost, or stolen, resulting in financial loss for the University. We have the following recommendations with regards to this observation: • Management should formally investigate the staff about the modification to the ticket

transaction, deposit tickets, and special access transaction payment and take appropriate action.

• Management should follow-up and resolve unpaid ticket transaction.

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• Management should reconcile Audience View ticket transactions to PayConex, and Banner Finance. Any variances should be reviewed, followed up, and resolved.

• Audience View should be configured to restrict the modification of the processed ticket transactions. Changes or updates should be entered as a void or refund and reprocessed as a new ticket transaction

Management Action Plan The following actions will be undertaken to address the above observation: • Management will review transactions referenced above for appropriateness and take action,

as appropriate. • Management will reconcile Audience View ticket transactions to PayConex, and Banner

Finance. Any variances will be reviewed, followed up, and resolved. • UNH Athletics Ticket Office staff will work with Audience View to adjust system

configurations to enhance controls over ticket processing and adjustments. Responsible Party: Deputy Athletic Director and Associate Athletic Director, Business Development Due Date: September 1, 2022 *3. Enhance cash handling and depositing process a. UNH Athletics is missing key cash and check handling, processing, and depositing

procedures. We also noted non-compliance with USNH Financial Services cash policies. There is a risk that the University’s cash may not be appropriately safeguarded. As a result, we noted the following key issues with Athletics cash handling, processing, and depositing:

• Checks received in the mail are not handled in dual custody and not stored in a secure location

• No log or tracking of cash or check received • Checks are not endorsed upon receipt • No sign-off at change of custody of cash/checks • Shared cash drawers • Untimely processing and depositing of cash receipts • Inadequate safeguard of cash • Inadequate identification and follow-up on variances between cash deposit amount

and Banner Finance • Cash funds not collected and dropped off in secure medium • Cash drops are not used to prevent excess cash maintained in drawers • No secure transportation of cash deposits including tamper proof bags • Lack of dual access controls in collection of deposits from drop box • Inadequate protocols to handle cash balance discrepancies • Inadequate process for the tracking, follow-up, recording, and resolution of cash

variances.

We also noted that there is inadequate segregation of duties over the receipt, deposit, and recording of cash receipts. The Assistant Athletic Director for Business Operations/Finance is responsible for receiving cash and checks, preparing the deposit, and completing the

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cash receipt journal voucher for upload into Banner Finance. When one person receives, deposits, and records cash receipts, the risk of fraud or malfeasance increases. There is the risk that cash receipts can be misappropriated, lost, or stolen without detection.

b. We noted that the controls over the access and management of change funds could be enhanced to safeguard cash and to comply with USNH Policy 04-003 Change Funds. Through our cash observation and inquiry, we noted the following:

• No tracking of outgoing and incoming cash activity in Whittemore Center change fund

• Lack of sign-off or dual cash count at receipt or return of change funds • Safes are not accessed under dual custody • Whittemore Box Office Safe is not properly secured and locked, even during busy

times • No tracking of staff with safe access privileges • Staff with access privileges are unaware on safe combination protocols • Safe combinations were not changed upon termination of Box Office Manager and

transition of safe custodian and responsible parties. • Surprise count of Whittemore Box Office change fund cash was short by $25. • No periodic documented count of Whittemore Center change cash. • Cash balance over $7,500 allowed to be maintained in personal possession by

athletic teams for extended periods of time without much record and follow-up • $600 in change funds stored at the Field House Box Office not locked in a safe or

strong box.

We also noted that the Whittemore Center Box Office Change fund has a balance of $8,000, which is in excess of what is required for daily cash operation needs. We noted an estimated Athletics daily cash change fund requirement appears to be much lower. According to USNH Policy 04-003, a change fund is should be established at an amount no greater than that which is required to conduct normal daily cash sales transactions. If the change fund is not used (or its use is reduced) for an extended period, the funds not needed are to be returned to the Cashier/Bursar Office. In addition, whenever change funds are not in use, they must be locked in a safe or kept in a locked strong box secured within a locked desk or file cabinet. There is the risk that cash is not adequately safeguarded, resulting in financial loss for the University.

c. We noted an instance where a team coach used their personal Venmo account to collect cash receipts related to a team fundraising event. The coach then reimbursed the University for the funds collected via a personal check. According to USNH policy 10-004, cash receipts are to be deposited intact and departments cannot commingle cash receipts with any other personal or business cash funds. These conditions exists because Athletics coaches and staff are not aware or trained on cash receipts policies. There is the risk that the University did not receive all funds collected for the fundraiser, resulting in financial loss.

d. We noted that cash receipt transactions were not consistently supported with adequate

documentation that agreed to the transaction posted in Banner Finance. According to USNH policy 02-210, cash receipts supporting documentation guidelines include a copy of the deposit slip, daily cash log, copies of receipts, daily cash register ledger, and support for application of receipts to outstanding accounts receivable. During testing of selected 15 bank deposit transactions, we noted the following issues:

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• Two transactions did not agree to the supporting POS system documentation. • One transaction where the amount on deposit ticket did not agree to the bank

deposit slip or Banner Finance Upload (FUPLOAD) entry. • Five transactions did not have point of service (POS) reports or a manual cash

receipt to support the cash receipt. • Five transactions were not independently reviewed and approved. • Supporting documentation for eight transactions was not maintained in Xtender.

These conditions exist due to the lack of review of cash receipt documentation for accuracy and compliance with USNH policies. There is the risk that cash is not adequately safeguarded, properly accounted for, complete, or accurate, resulting in financial loss for the University.

We have the following recommendations with regards to this observation:

• Management should develop Athletics cash collections policies and procedures that at a

minimum meet USNH cash handling policies, including the following elements, but not limited to:

o Mail opening o Check endorsement o Cash receipt tracking o Receipt issue (pre-numbered) and requirements o Supporting documentation and retention o Timely deposit requirements o Funds transfer receipting mechanism o Separate cash drawers o Periodic cash drops o Refunds and voids and required approvals o Cash transportation o Physical security/safeguarding of cash o Variance resolution o Reconciliation and recordkeeping requirements o Segregation of duties over cash collection, deposit, and reconciliation

• Management should develop change fund management procedures that align with USNH change fund policies, including the following elements, but not limited to:

o Tracking of incoming and outgoing change fund activity o Dual custody cash count and sign off at exchange of change fund cash o Periodic documented count of safe change funds o Security of cash and checks in off-site locations o Safe access and management o Overages/shortages tracking

• Management should formalize and document roles and responsibilities for UNH Athletics cash receipt handling, depositing, and recording, considering segregation of duties.

• Safe combinations should be changed. • Management should maintain a list of staff with designated access to safes and safe

combinations. • Management should evaluate daily cash requirements from the Whittemore Center Box

Office change fund and reduce, as appropriate. • Change fund variance should be resolved with USNH FOC-Accounting Services.

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• Training should be provided to staff responsible for handling, depositing, and recording of cash receipts.

• Management should consider the use of pre-numbered tamper proof cash bags. • Background checks should be performed on employees who have cash handling

responsibilities. • Critical cash handling tasks such as counting cash, picking up deposits at the Field

House drop box, and walking cash deposits to the bank or UNH Cashier should be handled under dual custody.

• Management should evaluate technologies available to reduce or eliminate cash collected in athletics ticketing, fundraising, parking, and other areas.

• Athletics staff and coaches should be informed that commingling of personal funds with University funds is not allowed. Staff who are identified as commingling funds should be formally notified of policy violation.

• Reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions.

Management Action Plan The following actions will be taken to address the above observation:

• Management will develop Athletics departmental policies and procedures, including cash

handling and processing and change fund management, incorporating elements defined above, to be completed by December 1, 2022.

• Management will evaluate organizational and staffing structure for effective and efficient processing of Athletics cash handling and depositing, while considering segregation of duties. As part of this process, management will formalize and document roles and responsibilities. Work to be completed by December 1, 2022.

• The Whittemore Box Office safe combination will be changed by July 1, 2022. Management will maintain a list of staff with authorized access to the safe and safe combination.

• Athletics management is working with UNH Finance to reduce the Whittemore safe change fund balance. As part of the reduction of the change fund balance, the variance in the change fund will be resolved with USNH FOC-Accounting Services. Work to be completed by July 1, 2022.

• Training will be provided to staff responsible for handling, depositing, and recording of cash receipts by September 1, 2022.

• Tamper-proof bags are now used by Athletics for the transportation of deposits to the bank or UNH Cashiers Office.

• All interns/staff have to go through PCI training and a background check before working in the Box Office. Athletics will validate and track that all student interns/staff are PCI trained and satisfied background checks prior to the start of 22/23 athletics season.

• Athletics management will evaluate staffing and minimize cash operations to reduce risk through the use of automation and self-service options, including mobile tickets.

• Athletics management is working with UNH Finance to identify vendor solutions to eliminate cash in Athletics 50/50 fundraising and parking operations. Work to be completed by July 1, 2022.

• Athletics management will notify coaches and staff that commingling of personal funds with University funds is not allowed by September 1, 2022.

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• Management will reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions. Work to be completed by December 1, 2022.

Responsible Party: Deputy Athletic Director, Assistant Athletic Director, Business Operations/Finance, and Associate Athletic Director, Business Development Due Date: Various – see due dates referenced above Internal Audit Response: The lack of dual custody over cash counts, pick up of deposits from the Field House drop box, and transportation of cash deposits increases the risk that funds are misappropriated, lost, or stolen. The risk can be mitigated by reducing cash operations, but residual risk still exists until all cash is eliminated. The acceptance of risk until cash is eliminated should be evaluated and signed off by the CFO. *4. Perform key reconciliations We noted that Athletics does not have adequate protocols in place to perform key reconciliations. Specifically, we noted following missing reconciliations: (1) ticket transactions sold in Audience View to Banner Finance, (2) football parking vouchers sold in Audience View to Banner Finance, (3) summer camp registrations in Destiny One to Banner Finance, (4) facility rentals in EMS to Banner Finance, (5) event registrations in IModules to Banner Finance, (6) athletic game guarantee and revenue share payments to contracts and Banner Finance, (7) fueling station sales in Red Card Athletics to Banner Finance, and (8) credit card transactions among PayConex, Banner Finance, bank account, and Audience View. We also noted that credit card transactions are not being periodically reconciled to ensure completeness and accuracy. During the audit, we noted the following issues with credit card transactions:

i. As of December 15, 2021, we noted an approximate variance of over $1.0 million in athletics ticket revenue and $93,000 in parking revenue between Audience View and Banner Finance. Most of these variances represent FY22 credit card transactions that have not been allocated to the appropriate FOAPAL. This partially occurred because Audience View was not properly configured to efficiently process and feed credit card payments into Banner Finance.

ii. Approximately $164,1060F

1 in unreconciled credit card transactions from the ski/skate sale fundraiser. We also noted an undetermined amount of Men’s Hockey golf tournament raffle/auction credit card transactions that were not properly credited to Friends of Men’s Hockey fundraising fund. Athletics was unable to validate that the ski/skate sale or Men’s Hockey golf tournament fundraising credit card transactions were recorded in Banner Finance and funds were appropriately deposited in a USNH bank account.

iii. Credit card chargebacks totaling $1,107 were not managed or analyzed.

1 Estimate is based upon the ski/skate sale summary provided by the Ski Team Coordinator. Internal Audit is unable to validate the estimate provided, as management does not have detail supporting documentation.

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These conditions exist because accounting and reconciliation job responsibilities were not transitioned from the Central Administration BSC to Athletics to ensure continuity. There is the risk that athletics revenue is incomplete, inaccurate, or misappropriated, resulting in financial loss for the University. We have the following recommendations with regards to this observation: • Management should develop procedures for periodic key reconciliations, including:

o Credit card transactions among Audience View, PayConex, bank account and Banner Finance,

o Ticketing transactions among Audience View and Banner Finance, o Revenues transacted in software applications used to manage Athletics activities

(Audience View, EMS, Destiny One, IModules, Red Card) to Banner Finance. • Management should reconcile FY22 revenue activity. • Management should develop a process for review and reconciliation of Athletics revenue

share contracts. • Management should develop procedures for the reconciliation of manual cash receipts to

Banner Finance. • Management should validate that credit card transaction funds were properly deposited in a

USNH bank account. Management should work with USNH Treasury and FOC Accounting Services to identify ski/skate sale credit card transactions in Banner Finance and adjust allocation of transactions to appropriate FOAPAL.

• Audience View should be configured to allocate credit card payments to the FOAPAL associated with the ticketed sporting event.

Management Action Plan The following actions will be taken to address the above observation:

• Athletics management will work with Audience View to configure system for efficient and

effective processing of ticket transactions, including allocation of ticket revenues to appropriate FOAPAL.

• Management will develop procedures for periodic key reconciliations, including: o Credit card transactions among Audience View, PayConex, bank account and

Banner Finance o Ticketing transactions among Audience View and Banner Finance o Revenues transacted in software applications used to manage Athletics activities

(Audience View, EMS, Destiny One, IModules, Red Card) to Banner Finance. • Management will reconcile FY22 revenue activity between sub-systems, PayConex, and

Banner Finance. • Athletics worked with UNH Finance to develop a process to track revenue share contracts

and associated payments. Contracts are reviewed on a periodic basis to ensure that revenue share payments are in accordance with contracts.

• Athletics will evaluate opportunities to minimize manual cash activities and leverage technology and credit card options. Work to be completed by December 1, 2022.

• Management will validate that credit card transaction funds were properly deposited in a USNH bank account. Management will work with USNH Treasury and FOC Accounting Services to identify ski/skate sale credit card transactions in Banner Finance and adjust allocation of transactions to appropriate FOAPAL.

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Responsible Party: Deputy Athletic Director and Assistant Athletic Director, Business Operations/Finance Due Date: July 1, 2022; unless otherwise noted Internal Audit Response: The absence of a process to reconcile manual cash receipts increases the risk that funds are misappropriated. The risk can be mitigated by reducing cash operations, but residual risk still exists until all cash is eliminated. The acceptance of risk until cash is eliminated should be evaluated and signed off by the CFO. *5. Enhance security of payment card data We noted that Athletics does not have procedures for the processing of payment card transactions, handling of related data, or a list of users with access to cardholder data to comply with USNH policy 10-010. We also noted that the login credentials for the PayConex credit card processing gateway were shared amongst all Box Office staff, including student interns. These credentials are saved in a Word document file on each Box Office computer. Payment Card Industry – Data Security Standard (PCI-DSS) Requirement 8 requires every authorized user to have a unique identifier and passwords must be adequately complex to ensure that whenever a user accesses cardholder data, that activity can be traced to the user and accountability can be maintained. We also noted that UNH Athletics accepted and processed credit card transactions for the ski/skate sale fundraiser; therefore, these payments are subject to compliance with PCI-DSS. We were informed by the Ski Team Coordinator and the Assistant Athletic Director for Business Operations/Finance that the Whittemore Box Office credit card swipe terminals were setup with computers at the UNH Track & Field Complex. Management was unaware as to the source of the computers used to connect the credit card swipe terminals and whether the computers were PCI-DSS compliant. Additionally, we noted that laptops are used in the Whittemore Center and Fieldhouse Box Office to process Box Office credit card ticket transactions. Laptops are portable and can be used to conduct other business activities. There is the risk that credit card data may not be secure, and UNH may not be in compliance with PCI -DSS, which may result in fines or loss of privilege to accept credit card payments. We have the following recommendations with regards to this observation: • Management should develop procedures for processing payment card transactions and

handling of related data to comply with USNH policy 10-010 USNH Payment Card Data Security.

• Individual user accounts should be setup in PayConex to comply with PCI DSS Requirement 8. Management should periodically review PayConex access for appropriateness.

• Management should work with USNH Treasury to review credit card swipe terminals and computers used in processing of Athletics credit card activity for compliance with PCI DSS requirements. Consider dedicated and secure computers for credit card processing.

• Management should discontinue the practice of storing username and password credentials in electronic shared files.

• PCI-DSS training should be provided to staff.

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• Background checks should be performed on employees and student interns who have access to PayConex.

Management Action Plan The following actions will be taken to address the above observation: • Athletics management will develop procedures for processing payment card transactions

and handling of related data to comply with USNH policy 10-010 USNH Payment Card Data Security. These procedures will be incorporated into the UNH Athletics Box Office desk manual.

• Individual user accounts will be setup in PayConex to comply with PCI DSS Requirement 8. • Management will periodically review PayConex access for appropriateness. • Athletics management will work with USNH Treasury to review credit card swipe terminals

and computers used in processing of Athletics credit card activity for compliance with PCI DSS requirements.

• Management will notify staff that user credentials should not be stored in electronic files. • Background checks are performed on employees and student interns who have access to

PayConex. Also, PCI-DSS training is provided to staff and student interns. Athletics management will work with USNH Treasury to track training to ensure that training is completed to meet PCI-DSS requirements.

Responsible Party: Deputy Athletic Director and Associate Athletic Director, Business Development Due Date: September 1, 2022 6. Enhance 50/50 raffle fundraising operations We noted that controls could be enhanced over 50/50 raffle fundraising. We noted inadequate protocols to effectively manage this fundraising and to ensure that funds are properly received and accounted for. Additionally, we noted that over/short balances are not consistently treated in accordance with USNH policy 04-003.B.3 which states that if the total cash at the close of the day does not agree with the authorized change fund amount plus the recorded receipts, the difference must be recorded in Banner as “cash over or short”. During testing, we noted one 50/50 raffle where a winner was not selected due to technical issues; rather proceeds were combined with the following evening raffle and a winner was selected. We also noted that the 50/50 AscendFS software application has not been configured to have systematic controls through the use of beginning and ending ticket numbers and control totals. Also, access to void 50/50 tickets is not restricted. There is the risk that 50/50 fundraising proceeds are lost, stolen, or misappropriated, resulting in financial loss for the University. Athletics completes IRS tax form W-2G with the raffle winner and gives the IRS copy of the W-2G to the winner. We noted that Athletics is not ensuring that the W-2G is complete and complies with IRS requirements. We also noted that the winner’s identification is not validated at the time of W-2G completion, as required. There is the risk that the University is not in compliance with IRS requirements, which can result in fines and penalties. Additionally, we noted that Athletics staff collects personal identifiable information from the 50/50 raffle winner. The winner completes the UNH Central Admin BSC Department 50/50

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Winner Verification Form, which requires the raffle winner’s SSN. We noted that there is no redaction of restricted data prior to imaging in Xtender. There is the risk that restricted information could be compromised or exposed, resulting in financial and reputational loss for the University. We have the following recommendations with regards to this observation: • Management should designate individual(s) responsible for 50/50 operations and to provide

oversight to Athletic teams running fundraiser. • Policies and procedures should be developed for 50/50 fundraising activities to include, but

not limited to: startup, voided transactions, reconciliation, reporting, variance resolution, and fundraising proceed allocation methodology.

• Training should be provided on 50/50 policies and procedures and AscendFS system operations to individuals processing and managing 50/50 fundraising sales.

• Management should configure the AscendFS 50/50 software to have systematic controls including use of beginning/ending ticket number to measure revenue completeness and control totals.

• Management should enforce USNH policy on cash overages/shortages. • Management should work with USNH FOC-Finance to develop protocols for the collection

and remittance of 50/50 raffle winner information for tax reporting. • Management should develop a requirement to redact sensitive information, where possible. Management Action Plan The following actions will be taken to address the above observation: • Management has terminated the contract with AscendFS 50/50 and is considering

automated cashless options for 50/50 fundraising. • Management will develop 50/50 policies and procedures. Management will consider the

handling payment of funds to the raffle winner and associated tax reporting when developing 50/50 protocols.

Responsible Party: Associate Athletic Director, Business Development Due Date: December 1, 2022 7. Enhance petty cash handling process We noted that the Athletics petty cash fund custodian on record with USNH was not updated when transitioned from the Central Administration BSC to the Athletics Administration Assistant. In addition, we noted that the balance in the petty cash parking fund of $25 did not agree to USNH petty cash records and Banner Finance, which has a balance of $50. Also, we noted that the petty cash account had not been used in during FY22. These conditions exist because Athletics does not have detailed procedures for the management of petty cash funds. There is the risk that petty cash is not safeguarded, resulting in financial loss for the University. We have the following recommendations with regards to this observation: • Management should review the use of Athletics petty cash operations and determine if petty

cash account is needed. If deemed necessary for operations, Athletics should formally

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update custodian and location of petty cash funds to comply with USNH policy. If not, Athletics should work with USNH FOC-Accounting Services to close the account.

• Petty cash variance should be resolved with USNH FOC-Accounting Services. Management Action Plan Management will work with USNH FOC – Accounting Services to close the petty cash account and resolve the petty cash variance.

Responsible Party: Assistant Athletic Director, Business Operations/Finance Due Date: July 1, 2022 V. Business Process Improvements

1. Enhance Box Office operations We noted that Box Office operations could be enhanced to best utilize UNH resources and reduce risk associated with ticket sales cash handling. We noted that 60% of weekday ticket operating days had five or less daily credit card or cash transactions. For the 15 days with 21 or more transactions, we noted that 75% had one or more ticketed athletic sporting events happening on campus that day.

During the period August 11, 2021 – December 15, 2021, online credit card ticket sales represented 64% of total ticket transactions (excluding student tickets).

0-5 6-10 11-15 16-20 21+# Days 50 5 11 3 15

0102030405060

# of

Day

s

# of Transactions

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We also noted that online tickets are more expensive than tickets purchased in-person at the Box Office. This is due to a per ticket transaction fee charged for online ticket purchases. With this pricing model, customers are disincentivized from purchasing tickets online. There is the risk that the Box Office service and pricing model are not aligned for the efficient processing of ticket transactions, while reducing the risks associated with processing cash ticket transactions at the Box Office. We have the following recommendations with regards to this observation: • Management should consider eliminating the cash ticket option at the Box Office. • Management should consider adjusting ticket pricing strategy to make tickets purchased

with cash more expensive than online and credit card ticket sales. • Management should review Box Office operations and adjust service model and hours, as

appropriate. • Management should review and update ticket pricing strategy to align with future transition

from paper ticketing to electronic ticketing (e-tickets).

Cash8%

Credit Card-Web64%

Manual Credit Card15%

No Pmt - Non-student

5%

OLD SYSTEM8%

Ticket Sales by Payment Type August 11, 2021 - December 15, 2021

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WEALTH ADVISORY | OUTSOURCING AUDIT, TAX, AND CONSULTING

Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor

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FY21 Single Audit ResultsJune 23, 2022

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Single Audit Results • Single Audit Report

o Opinion on internal controls over financial reporting and compliance in accordance with Government Auditing Standards

o Opinion on internal control over compliance with major program requirements in accordance with Uniform Guidance

o Major Programs Student Financial Aid CARES Act – Higher Education Emergency Relief Fund Title V – Coronavirus Relief Fund HHS - Every Student Succeeds Act/Preschool Development

o Findings No Material Weaknesses One Significant Deficiency – HEERF Reporting

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Office of Management and Budget (OMB)

• Approved HEERF funds to be designated as high risk again

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Questions and Feedback

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We welcome any questions pertaining to the single audit or other matters related to the engagement

We appreciate the opportunity to serve as the auditors for University System of New Hampshire

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WEALTH ADVISORY | OUTSOURCING AUDIT, TAX, AND CONSULTING

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Link to articles:https://www.claconnect.com/industries/education-overview

Brenda Scherer, CPASigning [email protected]

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UNIVERSITY SYSTEM OF NEW HAMPSHIRE BOARD OF TRUSTEES

Audit Committee

Motion Sheet

University System of New Hampshire To: Audit Committee Re: Accept External Auditors’ FY21 Uniform Guidance Audit Reports on USNH Federal

Expenditures

PROPOSED MOTION

MOVED, on recommendation of the Chief Administrative Officer, that the University System of New Hampshire Auditors’ Reports from CLA for the year ended June 30, 2021, as required by Title 2 of the U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards and Government Auditing Standards and Related Information, be accepted.

SUMMARY OF PROPOSED ACTION

The motion calls for acceptance of the University System of New Hampshire’s Auditors’ Reports required by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Act published by the U.S. Office of Management and Budget (OMB) in December 2013. This Act is often referred to as the new ‘Uniform Guidance’ rules. RATIONALE FOR PROPOSED ACTION

All non-federal entities that expend $750,000 or more of federal awards in a year are required to obtain an annual audit in accordance with the Uniform Guidance rules. PREVIOUS REVIEWS AND APPROVALS

The Chief Administrative Officer and Vice Chancellor for Financial Affairs & Treasurer, the Chief Financial Officers at each of the USNH institutions, the USNH Controller and other members of management have reviewed the results of the audit.

RELEVANT GOVERNANCE DOCUMENTS, POLICIES, AND PRACTICES

The Audit Committee charter states that one of the primary functions of the Audit Committee is to assist the Board of Trustees in fulfilling its oversight responsibilities relating to the integrity of the University System of New Hampshire’s financial statements. The controls tested as part of this audit are key factors ensuring the integrity of these statements. USNH BOT policy and bylaws refer to this responsibility as part of the Audit Committee’s charge.

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RESOURCE IMPLICATIONS

None

RISK MANAGEMENT CONSIDERATIONS

USNH would jeopardize federal funding for student financial aid programs, research, and other sponsored programs if it did not arrange for this audit to occur or if the audit disclosed significant problems with the administration or expenditure of federal funds. By regulation, this audit report must be provided to the federal government within 30 days of the auditors’ report date or by the end of March (for organizations with fiscal years ending June 30), whichever occurs earlier. For FY21, OMB has provided a 6 month single audit extension due to Covid-19.

SUBSEQUENT ACTION REQUIRED

With an anticipated audit report date and Audit Committee acceptance date of June 23, 2022, the USNH Controller will file the audit report and associated federal form with applicable federal agencies within 30 days of the auditors’ report date.

ATTACHED MATERIALS – SUMMARY AND SALIENT INFORMATION

A final draft of the University System of New Hampshire’s Auditors’ Reports required by the OMB Uniform Guidance rules is attached. The audited financial statements for the year ended June 30, 2021, previously reviewed by the Committee, are in the first section of the materials. This is followed by the Supplementary Schedule of Expenditures of Federal Awards and Related Notes. Expenditures of federal awards during fiscal year 2021 totaled $383 million. This includes student loans, direct aid, and workstudy funding totaling $188 million. By comparison, the fiscal year 2020 total of $332 million included $207 million of student loans, direct aid, and workstudy funding.

The second section of the materials includes the Auditor’s Reports on Internal Control over Financial Reporting, Compliance, and Other Matters, as well as the Auditor’s Report on Compliance for Major Program and Internal Control Over Compliance. There was one finding related to the CARES HEERF reporting requirement, whereas supporting documentation did not agree to the numbers included in the required report and posted via the institutions’ websites. KSC, GSC, and PSU’s management have reviewed the findings and are working to put new procedures in place to ensure USNH is fully compliant in these areas for future years.

SUBMITTED AND APPROVED BY:

Catherine Provencher Chief Administrative Officer and Vice Chancellor for Financial Affairs & Treasurer Date Prepared: June 14, 2022 For the Meeting of: June 23, 2022

-- End of Motion Sheet --

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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be Reproduced

UNIVERSITY SYSTEM OF NEW HAMPSHIRE

FINANCIAL STATEMENTS AND INDEPENDENT AUDITORS’ REPORT

(UNDER UNIFORM GRANT GUIDANCE)

YEAR ENDED JUNE 30, 2021

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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be Reproduced UNIVERSITY SYSTEM OF NEW HAMPSHIRE

TABLE OF CONTENTS YEAR ENDED JUNE 30, 2021

INDEPENDENT AUDITORS’ REPORT .................................................................................................................... 1

MANAGEMENT’S DISCUSSION & ANALYSIS ....................................................................................................... 3

FINANCIAL STATEMENTS .................................................................................................................................... 13

NOTES TO THE FINANCIAL STATEMENTS ........................................................................................................ 16

INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS ................................................................... 30

INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM, REPORT ON INTERNAL CONTROL OVER COMPLIANCE, AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE ................................... 32

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS ................................................................................ 35

NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS ............................................................. 66

SCHEDULE OF FINDINGS AND QUESTIONED COSTS ..................................................................................... 68

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INDEPENDENT AUDITORS’ REPORT

The Governor and Legislative Fiscal Committee, State of New Hampshire, and

The Board of Trustees University System of New HampshireUniversity System of New Hampshire - Single Audit

Report on the Financial Statements

We have audited the accompanying financial statements of the business-type activities and the aggregate discretely presented component unit of University System of New Hampshire (the System), as of and for the years ended June 30, 2021 and 2020, and the related notes to the financial statements, which collectively comprise the College’s basic financial statements as listed in the table of contents.

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditors’ Responsibility

Our responsibility is to express opinions on these financial statements based on our audits. We conducted our audits in accordance with auditing standards generally accepted in the United States of America and standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States. Those standards require that we plan and perform the audits to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditors’ judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.

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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be ReproducedThe Board of Trustees

University System of New HampshireUniversity System of New Hampshire - Single Audit

2

Opinions

In our opinion, the financial statements referred to above present fairly, in all material respects, the respective financial position of the business-type activities and the aggregate discretely presented component unit of University System of New Hampshire as of June 30, 2021 and 2020, and the respective changes in financial position and, where applicable, cash flows thereof for the years then ended, in accordance with accounting principles generally accepted in the United States of America.

Other Matters

Required Supplementary Information

Accounting principles generally accepted in the United States of America require that the Management’s Discussion and Analysis and the required supplementary information – retirement and OPEB plans, as listed in the table of contents, be presented to supplement the basic financial statements. Such information, although not a part of the basic financial statements, is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial reporting for placing the basic financial statements in an appropriate operational, economic, or historical context. We have applied certain limited procedures to the required supplementary information in accordance with auditing standards generally accepted in the United States of America, which consisted of inquiries of management about the methods of preparing the information and comparing the information for consistency with management’s responses to our inquiries, the basic financial statements, and other knowledge we obtained during our audit of the basic financial statements. We do not express an opinion or provide any assurance on the information because the limited procedures do not provide us with sufficient evidence to express an opinion or provide any assurance.

Other Reporting Required by Government Auditing Standards

In accordance with Government Auditing Standards, we have also issued our report dated October 25, 2021, on our consideration of University System of New Hampshire’s internal control over financial reporting and on our tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters. The purpose of that report is solely to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the University System of New Hampshire’s internal control over financial reporting or on compliance. That report is an integral part of an audit performed in accordance with Government Auditing Standards in considering University System of New Hampshire’s internal control over financial reporting and compliance.

CliftonLarsonAllen LLP

Quincy, Massachusetts October 25, 2021

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trustees voted to establish a single, merged college located in the Manchester-Con-cord corridor. The merged entity is intended to become a college within UNH and will retain the name Granite State College. A second key initiative of the integration will be to combine GSC and UNH online learning enterprises to strengthen, promote and expand online education for all USNH institutions. USNH leadership and the board continue to work with the State to facilitate the proposed merger activities.

USNH continues to offer on-campus and hybrid learning opportunities and again welcomed students back to the residential campuses this fall. USNH continues to focus on providing high-quality programs, safe campuses for our communities and those we serve, as well as plans for the future in the changing higher education market. The remainder of this report describes the results of financial operations for the year ended June 30, 2021, with comparisons to prior years.

III. Financial Highlights

A. RevenuesChart 1 below shows USNH’s revenue streams, including those classified as non-operating revenues per GASB standards, totaling over $1 billion in fiscal years 2021 and 2020. Given our tri-fold mission of instruction, research, and public service, the vast majority of USNH revenues are generated by providing educational and auxiliary services. Total gross revenues increased $46 million (4.5%) in fiscal year 2021. The largest increase was related to an increase in grants and contract revenue by 32% ($56 million), primarily due to the federal Cares Act for Higher Education Emergency Relief Fund (HEERF) and the State of NH Governor’s Office for Emergency Relief and Recovery (GOFERR) awards to mitigate costs related to COVID-19. For fiscal year 2021, USNH received $39 million in institutional HEERF awards, of which $19 million were unearned as of June 30, 2021, and expected to be realized during fiscal year 2022. GOFERR provided $28 million in aid during the fiscal year 2021, and $5 million in fiscal year 2020, for a total of $33 million to help mitigate costs related to COVID-19 pandemic.

Sales of auxiliaryservices $163 (15%)

Grants andcontracts $227 (21%)

Resident tuition,continuing

education andstate general

appropriations $269 (25%)

Nonresident tuition$303 (28%)

Noncapital gifts and endowment distributions$60 (6%)Student fees

$24 (2%)

Operating investmentincome and other revenues

$29 (3%)

Chart 1: 2021 Gross Revenues by SourceTotal = $1+ Billion($ in millions)

Management’s Discussion and AnalysisJune 30, 2021 and 2020 (Unaudited)

I. IntroductionThe following Management’s Discussion and Analysis summarizes the financial condition and results of activities of the University System of New Hampshire (USNH) for the fiscal years ended June 30, 2021 and 2020. This analysis provides a comparison of significant amounts and measures to prior periods and, where appropriate, presents management’s outlook for the future.

USNH is a Section 501(c)(3) corporation organized under the laws of the State of New Hampshire to serve the people of the State as the key provider of public higher education for bachelor’s and advanced degree students. USNH accomplishes its mission by operating four educational institutions that collectively offer a broad array of education, research, and public services for the State. These institutions include the University of New Hampshire (UNH), Plymouth State University (PSU), Keene State College (KSC), and Granite State College (GSC). While select programs are active in other regions as well as abroad, most of USNH’s activities take place at the three residential campuses (UNH Durham or UNHD, PSU, and KSC). UNH-Manchester and UNH Franklin Pierce School of Law (UNHM and UNHL), GSC and the UNH Cooperative Extension and Small Business Development Centers located throughout the State. The accompanying financial statements also include the activities and balances of the University of New Hampshire Foundation, Inc. (UNHF) and the Keene Endowment As-sociation (KEA), two legally separate but affiliated entities. (See Note 1 to the Financial Statements for additional information on affiliated entities.)

II. Economic OutlookThe COVID-19 pandemic exacerbated the already changing and challenging higher education environment. The impact of the pandemic was layered onto existing pre-pandemic trends such as declining demographics in both New Hampshire and New England, increases in student financial need, etc. USNH was and continues to be committed to the health and safety of students, faculty, staff, and all communities in which it operates. During fiscal year 2021, USNH successfully navigated the challenges of the COVID-19 pandemic and welcomed students to both in person and online instructional opportunities and college experiences. This accomplishment came at a significant financial cost as USNH spent approximately $64 million in pandemic-related costs, of which approximately $50 million was for surveillance testing. USNH received federal and state support to help offset a significant amount of the costs incurred during fiscal year 2021.

In June 2020, USNH leadership and the board of trustees adopted plans for a multi-year cost restructuring program for fiscal years 2021 through 2023 which targeted taking approximately 10% out of the cost structure by fiscal year 2023. Although the full 10% reduction may not be necessary by fiscal year 2023 based on other various factors including enrollment levels, state support, etc., the primary elements of the cost restructuring program which included general cost reduction initiatives, systemwide shared service initiatives as well as campus-specific initiatives will position USNH for the future beyond fiscal year 2023. The USNH board of trustees approved COVID enhanced voluntary separation incentive programs to help facilitate the necessary cost reductions and approximately 484 full-time benefited employees participated in that program and left USNH employment as of June 30, 2021.

USNH also continues to seek new opportunities to become more efficient and improve service levels which is demonstrated by another recent action. In July 2021, building on the complementary missions of Granite State College (GSC) and the University of New Hampshire Manchester (UNH Manchester), the USNH board of

3 I University System of New Hampshire

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University System of New Hampshire I 4

$200

$150

$100

$50

$02017 2018 2019 2020 2021

Financial aid - grants & contracts

Financial aid - institutional

Student loans advanced

As shown in Chart 2 below, institutional financial aid expenditures continue to surpass aid provided by grants and student loans issued. USNH has provided over $1.7 billion in direct institutional financial aid to students over the past ten years. Approximately $329 million (20%) of this total was from grants and contracts. Over $1 billion (73%) came from campuses’ general funds, and the remaining 7% ($123 million) was provided by gifts and athletics programs. USNH continues to focus on affordability of its offerings with the goal of limiting student and family loan debt. Also, for fiscal year 2021, students received $12 million in direct aid for COVID-19 pandemic relief.

As seen in Table 1 below, full-time equivalent (FTE) student enrollment has steadily declined 8.8% since fiscal year 2017 for all institutions combined mainly due to New England demographics and market changes. UNH’s Durham campus, despite the pandemic, had stable freshmen applications over the past three years as shown in Table 2.

Their enrollment strategy remains focused on attracting exemplary students, while adapting to the challenge of a pandemic. Approximately 51% of new UNHD students in the fall of 2020 ranked in the top 25% of their high school class reflecting the continued quality of the population. UNH continues to work on four strategic principles to drive UNH to become one of the top 25 public universities in the US. These include enhancing student success and well-being, expanding excellence, embracing New Hampshire, and building financial strength.

In fiscal year 2021, undergraduate tuition rates were held flat for NH students, and total nonresident tuition revenues increased 0.9% ($2.7 million) over the prior year. For the past three years, approximately 51% of USNH students were NH residents when calculated on a full-time equivalency basis. New England has historically been known as a premier location for the pursuit of higher education, whether at a public or private institution. While that is still true, regional school-age populations are expected to decrease over time, resulting in more competition for the smaller number of NH students.

USNH is working to ensure New Hampshire students are prepared to meet the needs of the State’s workforce. While financial aid from grants has remained consistent for the past several years, institutional financial aid grew 4.2% ($7.1 million) in fiscal year 2021 after a 3.1% ($5.0 million) increase in fiscal year 2020. USNH has also made significant changes in the way it awards financial aid. The Granite Guarantee program, which covers the cost of tuition for all federal Pell-grant eligible New Hampshire students, is now in its third year. This program is fund-ed with restricted gifts as well as unrestricted sources. The State is also partnering in this area by renewing its Governor’s Scholarship Fund for NH resident students. New

Hampshire’s school population data by age grouping suggests that our enrollment challenges will increase in future years. USNH continues to focus on multi-year planning to address the demographic and market changes ahead.

2017 2018 2019 2020 2021

UNH (all campuses) 15,473 15,669 15,629 15,141 14,750

PSU 4,641 4,694 4,772 4,409 4,260

KSC 4,160 3,758 3,487 3,434 3,111

GSC 1,584 1,446 1,468 1,444 1,452

Total USNH FTEs 25,858 25,567 25,356 24,428 23,573

NH Resident 13,240 12,940 12,842 12,413 12,067

Nonresident 12,618 12,627 12,514 12,015 11,506

Total USNH FTEs 25,858 25,567 25,356 24,428 23,573

2017 2018 2019 2020 2021

Freshmen applications received 19,076 18,397 18,474 18,040 18,797

Acceptances as % of applications 80% 83% 84% 84% 85%

Enrolled as % of acceptances 19% 20% 20% 18% 16%

* Comparable data for other campuses is available upon request.

Table 2: Freshman Applications, Acceptances and Enrollees at UNH Durham* For the Fall of Each Fiscal Year

Table 1: Full-Time Equivalent Credit Enrollment

For the Fall of Each Fiscal Year

Chart 2: Student Aid Trends ($ in millions)

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Student fees, gifts, grants and all other revenues

Nonresident tuition

Resident and continuing education tuition

State of New Hampshire general appropriations

Chart 3 below shows USNH’s major revenue stream trends for the past ten years. As seen in the graph, once the State appropriation was partially restored in fiscal year 2013, USNH held resident tuition rates flat from fiscal years 2013 through 2015. Inflationary increases in the resident tuition rates were added for fiscal years 2016 through 2020, and tuition held flat in fiscal year 2021. During fiscal year 2020, auxiliary revenue decreased by $48 million (22%) compared to fiscal year 2019, while the decrease in fiscal year 2021 was $4 million compared to fiscal year 2020. The fiscal year 2020 decrease was due to room and board refunds to students when residential campuses closed their dorms and dining facilities in response to the COVID-19 pandemic. Residential and dining halls re-opened in Fall 2020 following a hybrid model with less capacity, to accommodate social distancing and to provide quarantine facilities as well as lower demand primarily attributed to COVID. In fiscal year 2021, USNH revenues included one-time federal and State grant revenue of $60 million, including $39 million in student refund recoveries. As evidenced by the financial aid growth shown in Chart 2, USNH is committed to working with the State to ensure that New Hampshire’s students have access to quality education at an affordable price.

Chart 3: Ten Year Revenue History Before Application of Student Financial Aid ($ in millions)

B. ExpendituresUSNH’s expenses (including expenses classified as nonoperating per GASB standards) increased $80.3 million or 10% over the fiscal year 2020 level; and fiscal year 2020 expenses decreased by $8.2 million or 1% over fiscal year 2019. The grant supplies and services expense increase of $42 million (117.4%) was mainly driven by $25 million in testing and Personal Protective Equipment costs funded by the State of NH GOFERR award, and $12 million in student aid relief funded by HEERF. Nongrant compen-sation costs increased by $35 million (7.4%) primarily as a result of approximately 484 employees participating in COVID-related voluntary separation incentive programs approved by the USNH Executive Committee on June 11, 2020 for a total one time cost of $56 million in fiscal year 2021. Although the total cost was recognized in fiscal year 2021, the programs are salary continuation programs which delayed larger cash impact to fiscal year 2022. This cost was partially offset by salary savings realized in fiscal year 2021 which were generated as a result of restructuring initiatives as well as temporary savings associated with COVID.

During fiscal year 2021, USNH continued to develop multiple shared service centers for the System in the areas of procurement, information technology, financial services, human resources, research administration and other back-office and administrative services. The primary goals of the restructuring efforts include improved service, cost savings, increased efficiencies, and reduced risk. As part of the financial restructuring, USNH established a new Financial Operation Center (FOC) that serves all campuses in the areas of accounts payable (external vendors and employee travel), payroll, non-student accounts receivable and general accounting and financial reporting.


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Chart 4 displays USNH’s expenses for the past three fiscal years by functional, rather than natural, classification. The increases in financial aid discussed above are clearly depicted in the graph. The costs related to COVID-19 mitigation strategies and the voluntary separation incentive programs are reflected in all functional classifications, except for testing ($50 million), the most significant impact, reflected in the student services category (academic and student support) incurred during fiscal year 2021. Auxiliary services expense decreased $10 million over prior year as a result of a reduction in athletics and dining activity due to the hybrid model with a blend of in-person and online learning during the 2020-2021 academic year to mitigate the spread of COVID-19. (Additional detail on operating expenses by function can be found in Note 13 to the Financial Statements.)

C. Capital spendingThe campuses had several major capital projects completed during fiscal year 2021 which included the Campus heating and cooling improvement ($4 million), Kendall Hall renovation ($3 million), MacFarlane Greenhouse building renovation ($3 million), and improvements to Telecommunications Center ($3 million), all at UNH.

From fiscal years 2002 to 2013, USNH received significant state capital appropriations to renovate specific academic buildings on each campus. During the past ten years operating and internal funds totaling $130 million were used to supplement the state appropriations. Effective July 1, 2020, the State of New Hampshire appropriated $42 million in capital funds for the Biological Sciences Spaulding Hall at UNH, and KSC’s Elliot Student Service Success Center to be spent through June 30, 2025. For fiscal year 2020, $10 million of the state capital appropriation was used for the Biological Sciences Spaulding Hall at UNH. In fiscal year 2021, UNH spent $5 million of the $9 million state appropriation to add nursing program capacity with additional specializations in acute care and psychiatric mental health. The nursing program construction project began in fiscal year 2021. However, even with the additional state capital appropriation, there are still several buildings in need of improvement at each campus. USNH campuses must strategically prioritize the available limited funding for capital assets, while at the same time not allowing deferred maintenance needs to escalate. This work is needed

to ensure USNH can meet the education and experiential needs of its students. In addition, USNH is only authorized to issue debt for self-supporting, auxiliary projects. The related debt service is then funded by student fees for each type of auxiliary service (housing, dining, or recreation). For fiscal years 2021 and 2020, no new debt was issued.

Chart 5 below shows the funding sources for USNH’s capital spending over the past fifteen years. USNH spent over $1 billion during this time to construct and renovate buildings and infrastructure at all campuses. General funds of $504 million were the largest sources of funding of capital projects followed by debt issuances of $195 million. Plant and equipment depreciation expenses of $611 million were recorded during the same period. (See Notes 5 and 8 to the Financial Statements for additional information on property and equipment, and debt balances.)

Chart 4: Expenses by Functional Classication($ in millions)

$0 $50 $100 $150 $200 $250

Instruction

Student �nancial aid

Auxiliary services

Academic and student support

Research and public service

Depreciation

Operations and maintenance

Institutional support

Fundraising and communications

Interest expense

2020 = $1,032 Total 2019 = $1,037 Total 2021 = $1,119 Total

Chart 4: Expenses by Functional Classifications ($ in millions)

Chart 5: Capital Funding Sources, 2007-2021Total $1.4 Billion ($ in millions)

Gifts and grants$91 (7%)

Education andgeneral funds$504 (37%)

State capitalappropriations

$164 (12%)

Auxiliary funds$225 (16%)

Internal borrowings$197 (14%)

New debt$195 (14%)


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be ReproducedD. Investing Activities

Cash and short-term investment balances totaled approximately $216 million and $224 million on June 30, 2021 and June 30, 2020, respectively. (See Note 2 to the Financial Statements for additional information on cash, cash equivalents and short-term investments.) USNH’s long-term investments are primarily derived from endowment gifts intended to be invested in perpetuity. With Board approval USNH also invests select large, current-use gifts, and unrestricted balances held centrally, as quasi-endowment funds. These amounts are invested in one of three venues depend-ing on whether the donor contributed to a campus, the UNH Foundation (UNHF), or the Keene Endowment Association (KEA). The investment pools are managed to provide the highest rate of return over the long term given an acceptable level of risk as determined by the responsible fiduciaries. The USNH Consolidated Endowment Pool holds funds for the benefit of all campuses. The UNHF endowment pool holds funds for the benefit of UNH only, and the KEA pool holds funds for the benefit of KSC only. The USNH Board of Trustees has fiduciary responsibility for the USNH Pool, whereas the separate boards of UNHF and KEA have their own investment policies and are responsible for those investments. Below is a summary of USNH’s endowment and similar investment values for the past three years.

2021 resulted in a decrease in these underwater funds. Of the 1,565 endowment funds maintained in the various endowment pools, 3 remained underwater at June 30, 2021. This compares to 123 underwater endowment funds at June 30, 2020. The endowment funds were underwater by $397,000 at June 30, 2021, compared to $2 million at June 30, 2020. (See Notes 4 and 12 for further information on endowment and similar investments.)

IV. Using the Financial Statements

A. Statements of Net PositionThe Statements of Net Position depict all USNH assets, liabilities, and deferred inflows/outflows of resources on June 30 each year, along with the resulting net financial position. An increase in net position over time is a primary indicator of an institution’s financial health. Factors contributing to future financial health as reported on the Statements of Net Position include the value and liquidity of financial and capital investments, and balances of related obligations.

Table 3: Endowment and Similar InvestmentsMarket Value Summary ($ in millions)

As of June 30,

2021 2020 2019

USNH Pool $ 663 $534 $542

UNHF Pool 297 236 236

KEA Pool 17 14 10

Funds held in trust 19 15 16

Life Income/Annuity Funds 5 4 5

$1,001 $803 $809

Table 4: Pooled Endowment Returns Year - Ended June 30, Three Year

2021 2020 2019 Average USNH Pool

Gross return 29.3% 1.9% 6.3% 12.5%

Investment management fees (0.6%) (0.5%) (0.5%) (0.5%)

Net return 28.7% 1.4% 5.8% 12.0%

Distributions (4.5%) (4.2%) (4.1%) (4.3%)

Net reinvested 24.2% (2.8%) 1.7% 7.7%

UNHF Pool

Gross return 29.4% 1.9% 5.6% 12.3%


Net return 28.3% 1.1% 5.0% 11.5%

Distributions (5.6%) (5.2%) (3.8%) (4.9%)

Net reinvested 22.7% (4.1%) 1.2% (6.6%)

KEA Pool

Gross return 23.3% 4.8% 10.9% 13.0%


Net return 22.5% 4.1% 10.2% 12.3%

Distributions (3.2%) (4.3%) (4.5%) (4.0%)

Net reinvested 19.3% (0.2%) 5.7% 8.3%

While the two larger pools are primarily invested in funds, the KEA pool primarily holds individual stock and bond investments. As shown in Table 4 to the right, the KEA pool net gains over the past three years averaged 12.3% and the USNH and UNHF pools averaged 12.0% and 11.5%, respectively, before distributions. During fiscal year 2019, the Investment Committee of the USNH Board of Trustees voted to change the target asset allocations for investments in the USNH Endowment pool. The changes included increasing the targets for public and private global equities, while also reducing the targeted level of flexible capital investments. These changes will be incorporated over several years to ensure prior fund commitments are met. All three pools’ returns benefited from the historically high market valuations during fiscal year 2021.

Distributions from the endowment and trust funds totaled approximately $38 million in fiscal year 2021. This compares to $35 million for fiscal year 2020. The difference is primarily due to USNH beginning to payout on a quasi-endowment created several years ago to support systemwide debt service payments. Distribu-tions of approximately $25 million were made from the USNH pool and trusts, along with $13 million from the UNHF pool and $436,000 from the KEA pool. Distributions represent a smaller percentage of the USNH pool because USNH holds several quasi-endowment funds for future, rather than current use. Volatility in returns has resulted in a limited number of endowment funds having market values less than the original gift value (“underwater” funds). The net positive returns for fiscal year


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Table 5: Condensed Information from the Statements of Net Position as of June 30, ($ in millions)

2017 2018* 2019** 2020 2021

Cash and short-term investments $ 213 $ 206 $ 224 $ 224 $ 216 Endowment and similar investments 730 781 809 803 1,001 Property and equipment, net 1,120 1,122 1,117 1,120 1,101 Other assets and deferred outflows of resources 106 95 92 107 105 Total Assets and Deferred Outflows of Resources 2,169 2,204 2,242 2,254 2,423

Derivative instruments - interest rate swaps 26 18 23 29 22 Postretirement medical benefits 56 90 83 91 86 Long-term debt 501 488 465 439 412 Other liabilities and deferred inflows of resources 152 160 173 198 245 Total Liabilities and Deferred Inflows of Resources 735 756 744 757 765

Net investment in capital assets 651 665 685 709 722 Restricted financial resources 454 481 495 497 606 Unrestricted financial resources 329 302 318 291 330 Total Net Position $1,434 $1,448 $1,498 $1,497 $1,658

*Beginning net position restated to reflect the adoption of GASB 75 related to postretirement medical obligations**Beginning net position restated to reflect the adoption of GASB 83 related to asset retirement obligations

As shown above, cash and short-term investment balances have been relatively stable over the past five years. In fiscal year 2017, endowment returns rebounded after net losses in the prior two years. The endowment gains were more moderate in fiscal years 2018 and 2019, slightly decreased in fiscal year 2020, and a large increase in fiscal year 2021, but overall increased $271 million (37%) since fiscal year 2017, primarily due to favorable returns. Property and equipment, net, decreased in FY21 as capital expenditures were less than annual depreciation expense.

Deferred inflows and outflows of resources include changes in the fair value of USNH’s interest rate swap derivatives, as well as accounting gains and losses related to refinancing certain bonds outstanding. The impacts of changes in actuarial assumptions, differences between projected and actual earnings, and benefit pay-ments made after the measurement dates of USNH benefit plans are also included in deferred inflows and outflows beginning in fiscal year 2017 depending on the type of plan.

In fiscal year 2021, USNH completed a roll forward of the 2020 biennial actuarial valuation according to the provisions of GASB Statement No. 75, Accounting and Financial Reporting for Postemployment Benefits Other than Pensions, for our postre-tirement medical obligations. The result was an increase of $5 million in deferred outflows of resources due to a decrease of the discount rate used. The fair value of interest rate swap obligations resulted in an $7 million decrease in deferred outflows.

In fiscal year 2018, the UNH Foundation also adopted the provisions of GASB Statement No. 81, Irrevocable Split-Interest Agreements, which resulted in recording deferred inflows of approximately $1 million and $2 million in fiscal years 2017 and 2018, respectively.

USNH has large liabilities related to long-term debt, postretirement medical ben-efits, and added in fiscal year 2021 $40 million ($56 million total, net of $16 million paid in fiscal year 2021) in new liabilities related to one-time separation incentives programs. Bond and capital lease principal payments ranged from $21 million to $25 million for fiscal years 2019 through 2021. The postretirement obligations represent the actuarially determined value of medical benefits provided to certain current and former employees for various periods, including the remaining life of the participants in some cases. (See Notes 7 and 8 to the Financial Statements for additional information in this regard.) The other liabilities balance above includes accounts payable, accrued employee benefits, government advances refundable under the Perkins Loan Program, interest rate swap liabilities related to derivative instruments and unearned revenue. The decrease in unearned revenue in fiscal year 2021 is mainly due to $14 million of student refunds in fiscal year 2020 related to COVID-19 campus closures that students elected to apply to the fall 2021 semester.

Table 5 below shows condensed information from the Statements of Net Position at June 30 for the past five years. Note that we have also included certain condensed information as of June 30, 2021 by campus herein as required by regional accreditation agencies.


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B. Statements of Revenues, Expenses and Changes in Net PositionThis statement reports total operating revenues, operating expenses, other revenues and expenses, and other changes in net position, as prescribed and defined by the Governmental Accounting Standards Board (GASB). There are three major components which management considers separately when analyzing the increase (decrease) in total net position: increase (decrease) in Net Position Before Other Changes (also referred to as operating margin); capital appropriations and other plant changes; and endowment gifts and net returns. The increase (decrease) in Net Position Before Other Changes is further broken down into operating and nonoperating as prescribed by GASB reporting standards which require that certain USNH recurring revenues be shown as nonoperating. This includes state general appropriations, federal Pell grants, noncapital gifts, operating investment income, the portion of endowment returns used to fund the related programs, and other revenue sources that are defined as nonoperating revenues by GASB. These revenue streams are important sources of funds used to supplement tuition and fees revenue. Accordingly, operating and nonoperating revenue and expense, together, constitute the indicator of recurring revenues and expenses for USNH.

Cash and short-term investments $ 185 $ 30 $ 20 $24 $ (43) $ 216Endowment and similar investments 508 38 54 10 391 1,001Property and equipment, net 744 184 165 7 1 1,101Other assets and deferred outflows of resources 59 5 7 1 33 105 Total Assets and Deferred Outflows of Resources 1,496 257 246 42 382 2,423

Derivative instruments - interest rate swaps – – – – 22 22Postretirement medical benefits 62 11 10 2 1 86Long-term debt 163 92 88 – 69 412Other liabilities and deferred inflows of resources 117 26 22 2 78 245 Total Liabilities and Deferred Inflows of Resources 342 129 120 4 170 765

Net investment in capital assets 579 92 76 7 (32) 722Restricted financial resources 510 27 58 11 – 606Unrestricted financial resources 65 9 (8) 20 244 330 Total Net Position $1,154 $ 128 $126 $38 $212 $1,658

University ofNew Hampshire

Campuses &Foundation

Plymouth State

University

Keene StateCollege &

EndowmentAssociation

GraniteState

College

System-wide

Office

Total University

System of New Hampshire

Table 5A: Condensed Information from the Statement of Net Position as of June 30, 2021Presented by Campus($ in millions)

Net position is reported in three categories. The net invested in capital assets amount represents the historical cost of property and equipment reduced by total accumulated depreciation and the balance of related debt outstanding for certain auxiliary buildings. Restricted financial resources include balances of current and prior year gifts for specified purposes such as scholarships or academic programs, as well as campus endowment balances which were required to be invested in perpetuity by the original donors ($307 million and $296 million at June 30, 2021 and 2020, respectively). Unrestricted financial resources represent net assets that are available for any future use without legal restriction. (See Note 14 to the Financial Statements for further details on the components of net position.) A breakdown of asset, liability, and net position balances by campus as of June 30, 2021 is shown below.


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2017 2018 2019 2020 2021

OPERATING REVENUES Tuition and fees $501 $514 $522 $517 $508 Less: student financial aid (172) (188) (197) (200) (207) Net tuition and fees 329 326 325 317 301Grants and contracts 121 127 129 131 144Sales of auxiliary services 216 215 215 166 162Other operating revenue 30 30 32 29 26 Total Operating Revenues 696 698 701 643 633

OPERATING EXPENSES Employee compensation 520 533 535 538 578Supplies and services 210 208 204 191 234 Utilities, depreciation and amortization 81 84 84 87 85 Total Operating Expenses 811 825 823 816 897 Operating loss (115) (127) (122) (173) (264)

NONOPERATING REVENUES (EXPENSES) State of New Hampshire general appropriations 81 81 81 86 89Other nonoperating grant revenue 25 26 26 41 83Noncapital gifts, investment income and other revenues 41 44 56 59 62Interest expense, net (20) (18) (17) (16) (15) Total Nonoperating Revenues (Expenses) 127 133 146 170 219 Increase (Decrease) in Net Position Before Other Changes 12 6 24 (3) (45)

OTHER CHANGES IN NET POSITION Endowment gifts and returns, net 70 45 27 (10) 197State capital appropriations and other changes 11 5 2 12 9 Total Other Changes in Net Position 81 50 29 2 206 Effect of adoption of new accounting standards – (42) (2) - - Total Increase (Decrease) in Net Position $ 93 $ 14 $ 51 $ (1) $161

Table 6: Condensed Information from the Statements of Revenues, Expenses and Changes in Net Positionfor the Years Ended June 30, ($ in millions)

Table 6 shows condensed information from the Statements of Revenues, Expenses and Changes in Net Position for the five years ended June 30, 2021.

The net tuition and fees revenue in these statements reflects revenue earned from enrolled students for academic programs, classes, and related fee-based services. Auxiliary services revenues reflect self-supporting activities which provide non-instructional support in the form of goods and services to students, faculty, and staff upon payment of a specific user charge or fee. These services include housing, dining, Division I athletics, health, recreation, transportation, student union and other programs. Grants and contracts revenues reflect amounts reimbursed by USNH sponsors including the US government, State of New Hampshire, and other entities. These revenues may also come from awards to other institutions that are later contracted out to USNH campuses.

Net tuition and fees decreased because of lower undergraduate enrollment and higher student financial need. Operating grants and contracts increased due to an increase in grants awarded to UNH from various state programs. Nonoperating revenues were up $42 million in fiscal year 2021, primarily due to an increase in grant revenue for recovery of COVID-related auxiliary refunds issued in fiscal year 2020 and 2021 as well as COVID testing and safety-related expenses. The State

of NH appropriations increased to allow USNH to freeze undergraduate in-state tuition. Endowment gifts totaled $10 million in fiscal year 2021, $15 million in fiscal year 2020, and $18 million in fiscal year 2019. The investment return after distributions resulted in gains of $187 million in fiscal year 2021 after losses of $24 million in fiscal year 2020 and gains of $9 million in fiscal year 2019. The volatility of endowment returns is a significant driver of the change in total net position each year. Operating expenses were up $80 million in fiscal year 2021, after a decrease of $8 million in fiscal year 2020. The increase in expenses is mainly due to the cost of the voluntary separation incentive programs, and COVID-related expenses such as testing, PPE, etc., net of savings from restructuring and temporary reductions.

The increase(decrease) in net position before other changes reflects USNH’s operating margin each year. USNH’s operating margin for fiscal year 2021 was (5.1%) of net revenues. This is primarily due to costs related to COVID-19 pandemic, and the new separation incentive programs that resulted in approximately 10% reduction of force as of June 30, 2021, as discussed previously.

Table 6A on the following page provides condensed information from the Statements of Revenues, Expenses and Changes in Net Position presented by campus for the year ended June 30, 2021.


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OPERATING REVENUES Tuition and fees $365 $ 73 $ 55 $15 $ – $508 Less: student financial aid (148) (29) (24) (6) – (207) Net tuition and fees 217 44 31 9 – 301Grants and contracts 132 3 6 3 – 144Sales and auxiliary services 109 28 25 – – 162 Other operating revenue 17 3 1 – 5 26 Total Operating Revenues 475 78 63 12 5 633

OPERATING EXPENSESEmployee compensation 427 58 65 13 15 578Supplies and services 138 32 35 5 24 234Utilities, depreciation and amortization 58 15 12 – – 85 Total Operating Expenses 623 105 112 18 39 897Operating loss (148) (27) (49) (6) (34) (264)

NONOPERATING REVENUES (EXPENSES)State of New Hampshire general appropriations 60 13 12 4 – 89Other nonoperating grant revenue 33 11 8 3 28 83Noncapital gifts, investment income and other revenues 48 3 4 1 6 62Interest expense, net (7) (3) (3) – (2) (15) Total Nonoperating Revenues (Expenses) 134 24 21 8 32 219 Increase (Decrease) in Net Position Before Other Changes (14) (3) (28) 2 (2) (45)

OTHER CHANGES IN NET POSITION Endowment gifts and returns, net 101 8 11 2 75 197State capital appropriations and other changes 19 3 2 – (15) 9 Total Other Changes in Net Position 120 11 13 2 60 206 Total Increase (Decrease) in Net Position $106 $ 8 $ (15) $ 4 $58 $161

University ofNew Hampshire

Campuses &Foundation

PlymouthState

University

Keene StateCollege &

EndowmentAssociation

GraniteState

College

System-wide

Office

Total University

System of New Hampshire

Table 6A: Condensed Information from the Statement of Revenues, Expenses and Changes in Net Position for the Year Ended June 30, 2021 Presented by Campus ($ in millions)

C. Statements of Cash FlowsThe Statements of Cash Flows summarize transactions affecting cash and cash equivalents. Table 7 below shows summary information from the Statements of Cash Flows for the five years ended June 30, 2021.

2017 2018 2019 2020 2021

Cash flows from: Receipts from tuition and fees, net $332 $328 $327 $348 $289 Receipts from sales of auxiliary services 217 214 216 165 164 Receipt of state general appropriations 81 81 81 86 89 Noncapital gifts, grants and other receipts 188 203 198 212 282 Payments to and on behalf of employees (543) (537) (532) (532) (533) Payments for supplies, services and utilities (227) (227) (222) (211) (252) Net Cash Provided by Operating and Noncapital Financing Activities 48 62 68 68 39 Net Cash Used in Capital Financing Activities (120) (83) (78) (90) (76) Net Cash Provided by Investing Activities 69 10 30 12 57 Increase/(Decrease) in Cash and Cash Equivalents $ (3) $ (11) $ 20 $ (10) $ 20

Table 7: Condensed Information from the Statements of Cash Flows for the Years Ended June 30,($ in millions)


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be ReproducedThese statements provide information about cash collections and cash payments made by USNH each year. The statements are designed to help readers assess our

ability to generate the cash flows necessary to meet current and future obligations. Cash flows from operating activities will always be different than the operating results on the Statements of Revenues, Expenses and Changes in Net Position because of the inclusion of noncash items, such as depreciation expense, and because the latter statement is prepared on the accrual basis of accounting, meaning that it shows revenues when earned and expenses as incurred. Despite significant focus on cash preservation during fiscal year 2021, the decrease in net cash flows provided by operating and noncapital financing activities is primarily related to COVID-19 pandemic including response and mitigation costs. The reduction over the prior year of receipts from tuition and fees resulted from multiple factors, including lower fiscal 2021 accrual-based tuition and fee revenue ($16 million) and the timing of when tuition and fee payments were received. As a result of COVID, in fiscal year 2020, USNH issued student refunds of approximately $40 million of which the majority related to auxiliary services such as housing and dining. Only approximately half of those refunds were taken by students in cash in fiscal year 2020 and the remaining portion of approximately $18 million, as requested, was left on student accounts, and deemed to be what students elected to carry forward to cover tuition and fees in subsequent years; therefore, increasing fiscal year 2020 tuition and fee receipts by $18 million. In fiscal year 2021, approximately $14 million of the $18 million carryforward refunds (deposits) was used to cover tuition and fees in the fiscal year 2021, resulting in less cash collec-tion during fiscal year 2021. Additionally, cash receipts generally received for 2021 summer programs (deemed to be fiscal year 2022 revenue deposits) were much lower than prior years which is significantly attributed to of COVID. The net cash used in capital financing activities for fiscal year 2021 decreased primarily due to less construc-tion spend as a result of continued cash preservation efforts employed to address the uncertainty associated with the COVID pandemic. The cash provided by investing activities in fiscal year 2021 is higher because of investment market increase in fiscal year 2021.

D. Financial IndicatorsUSNH uses certain Moody’s leverage ratios as primary indicators of financial health. The UFR to Debt ratio uses the unrestricted net position balance as the numerator and the outstanding long term debt balance (defined as total long term debt net of unamortized discounts/premiums) as the denominator. The Spendable Cash and Investments to Debt (SCI to Debt) ratio uses wealth that can be accessed over time or for a specific purpose to repay bondholders. USNH’s historically targeted unrestricted financial resources to debt ratio is 50% or above, and the targeted SCI to Debt ratio is 1.3 or above. The average of UFR to Debt over the past five years was 73%, and 1.70 for the SCI to Debt ratio. The 2021 increase above the historical averages in these ratios is due to higher than normal investment market valuations. Both ratios reflect sufficient available support for ongoing initiatives. (See Notes 8 and 14 to the Financial Statements for additional information in this regard).

Chart 6: Ratios

For further information about these financial statements, contact the University System of New Hampshire, Financial Affairs (603-862-2260), 5 Chenell Drive, Suite 301, Concord, NH 03301

20182017 2019 2020 2021

65.8% 72.9% 70.5%

85.3%

1.521.65 1.70

2.27

Spendable Cash and Investments to Debt

Unrestricted Financial Resources to Debt

1.35

68.4%


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be Reproduced University System of New Hampshire

Statements of Net Position($ in thousands)

Balance at June 30, 2021 2020

ASSETS Current Assets Cash and cash equivalents $ 85,670 $ 65,339 Short-term investments 130,477 158,907 Accounts receivable, net 27,037 31,298 Pledges receivable - current portion 2,549 2,537 Notes receivable - current portion 1,742 2,070 Prepaid expenses and other current assets 9,903 7,415 Total Current Assets 257,378 267,566 Noncurrent Assets Endowment and similar investments - campuses 682,429 549,393 Endowment and similar investments - affiliated entities 318,818 253,526 Pledges receivable, net of current portion 7,131 3,936 Notes receivable, net of current portion 8,323 11,070 Pension assets, net of obligations 1,557 432 Property and equipment, net of accumulated depreciation 1,101,440 1,119,925 Total Noncurrent Assets 2,119,698 1,938,282 TOTAL ASSETS 2,377,076 2,205,848

DEFERRED OUTFLOWS OF RESOURCES 46,463 48,775

LIABILITIES Current Liabilities Accounts payable and accrued expenses 81,510 64,113 Deposits and unearned revenues 56,012 68,879 Accrued employee benefits - current portion 37,462 6,673 Postretirement medical benefits - current portion 5,342 4,412 Long-term debt - current portion 30,675 27,315

Total Current Liabilities 211,001 171,392

Noncurrent Liabilities Asset retirement and other obligations 13,847 10,646 Refundable government advances 10,715 13,229 Accrued employee benefits, net of current portion 33,926 24,467 Postretirement medical benefits, net of current portion 80,797 86,131 Derivative instruments - interest rate swaps 22,280 29,262 Long-term debt, net of current portion 381,003 411,678 Total Noncurrent Liabilities 542,568 575,413

TOTAL LIABILITIES 753,569 746,805

DEFERRED INFLOWS OF RESOURCES 11,346 10,474

NET POSITION (see Note 14) Net investment in capital assets 722,339 709,337 Restricted Nonexpendable 306,566 296,353 Expendable 299,440 200,667 Unrestricted 330,279 290,987 TOTAL NET POSITION $1,658,624 $1,497,344

See accompanying notes to the financial statements.


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Statements of Revenues, Expenses and Changes in Net Position($ in thousands)

For the year ended June 30, 2021 2020

OPERATING REVENUES Resident tuition $ 163,329 $ 166,003 Nonresident tuition 302,827 305,555 Continuing education tuition 17,572 19,222 Student fees revenue 24,329 26,148 Total tuition and fees 508,057 516,928 Less: student financial aid - grants and contracts (31,759) (31,922) Less: student financial aid - all other (175,463) (168,333) Net tuition and fees 300,835 316,673 Grants and contracts - direct revenues 120,066 108,488 Grants and contracts - facilities & administrative recovery 24,128 22,363 Sales of auxiliary services 162,460 166,370 Other operating revenues 26,221 28,921 TOTAL OPERATING REVENUES 633,710 642,815

OPERATING EXPENSES Employee compensation - grants and contracts 69,900 64,791 Employee compensation - all other 508,122 473,209 Supplies and services - grants and contracts 77,697 35,738 Supplies and services - all other 156,347 154,823 Utilities 15,776 18,059 Depreciation and amortization 68,953 69,015

TOTAL OPERATING EXPENSES 896,795 815,635 Operating loss (263,085) (172,820)

NONOPERATING REVENUES (EXPENSES) State of New Hampshire general appropriations 88,500 85,500 Federal Pell grants 23,084 24,440 Other nonoperating grant revenue 60,073 16,429 Noncapital gifts 22,366 17,411 Endowment and investment income 38,882 41,667 Interest expense, net (15,432) (16,330) Other nonoperating revenue 1,200 137

TOTAL NONOPERATING REVENUES (EXPENSES) 218,673 169,254 DECREASE IN NET POSITION BEFORE OTHER CHANGES (44,412) (3,566)

OTHER CHANGES IN NET POSITION State of New Hampshire capital appropriations 4,562 10,082 Plant gifts, grants and other changes, net 4,513 1,693 Endowment and similar gifts 9,717 14,719 Endowment return, net of amount used for operations 186,900 (24,130)

TOTAL OTHER CHANGES IN NET POSITION 205,692 2,364

INCREASE (DECREASE) IN NET POSITION 161,280 (1,202) NET POSITION AT BEGINNING OF YEAR 1,497,344 1,498,546

NET POSITION AT END OF YEAR $1,658,624 $1,497,344



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Statements of Cash Flows($ in thousands)

For the year ended June 30, 2021 2020

CASH FLOWS FROM OPERATING ACTIVITIES Receipts from tuition and fees, net of student financial aid $ 289,573 $348,306 Receipts from sales of auxiliary services 163,582 164,603 Receipts from grants, contracts and other operating revenues 170,209 154,421 Payments to employees (389,744) (401,392) Payments for employee benefits (143,329) (130,909) Payments for supplies, services and utilities (251,579) (210,722)

NET CASH USED IN OPERATING ACTIVITIES (161,288) (75,693)

CASH FLOWS FROM NONCAPITAL FINANCING ACTIVITIES State general appropriations 88,500 85,500 Federal Pell and other nonoperating grants 93,133 39,318 Noncapital gifts 19,160 18,488

NET CASH PROVIDED BY NONCAPITAL FINANCING ACTIVITIES 200,793 143,306

CASH FLOWS FROM CAPITAL FINANCING ACTIVITIES State appropriations for plant projects 30 10,052 Plant gifts and grants 4,660 5,199 Endowment gifts 9,717 14,720 Proceeds from issuance of debt and sale of property 2,706 – Debt principal payments (25,404) (24,292) Interest payments (16,619) (17,870) Purchases and construction of property (51,455) (77,823)

NET CASH USED IN CAPITAL FINANCING ACTIVITIES (76,365) (90,014)

CASH FLOWS FROM INVESTING ACTIVITIES Proceeds from sales of investments 435,196 445,894 Purchases of investments (383,523) (440,107) Investment income 5,518 6,531

NET CASH PROVIDED BY INVESTING ACTIVITIES 57,191 12,318

INCREASE (DECREASE) IN CASH AND CASH EQUIVALENTS $ 20,331 $ (10,083) BEGINNING CASH AND CASH EQUIVALENTS 65,339 75,422

ENDING CASH AND CASH EQUIVALENTS $ 85,670 $ 65,339

RECONCILIATION OF OPERATING LOSS TO NET CASH USED IN OPERATING ACTIVITIES Operating loss $ (263,085) $(172,820) Adjustments to reconcile operating loss to net cash used in operating activities: Depreciation and amortization 68,953 69,015 Changes in assets and liabilities: Accounts receivable, net (505) (3,689) Notes receivable 560 (935) Prepaid expenses and other current assets (2,488) 1,815 Accounts payable and accrued expenses 15,933 7,976

Deposits and unearned revenues (12,346) 24,787 Accrued employee benefits 31,690 (1,842)

NET CASH USED IN OPERATING ACTIVITIES $(161,288) $ (75,693)

SIGNIFICANT NONCASH TRANSACTIONS Endowment return, net of amount used for operations $ 186,900 $ (24,131) Loss on disposal of capital assets (147) (2,962)

Construction services payable balance 7,456 5,681



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Notes to the Financial Statements

June 30, 2021 and 2020

1. Summary of significant accounting policies and presentationThe University System of New Hampshire (USNH) is a not-for-profit institution of higher education created in 1963 as a body politic and corporate under the laws of the State of New Hampshire (the State) and is generally exempt from income taxes under Section 501(c)(3) of the Internal Revenue Code. USNH is considered a component unit of the State for financial reporting purposes. The accompanying financial statements include the accounts of the University of New Hampshire (UNH), Plymouth State University (PSU), Keene State College (KSC), and Granite State College (GSC) as well as certain affiliated entities discussed below. UNH, PSU, KSC and GSC are collectively referred to in the accompanying financial statements as “campuses.”

Affiliated entities and related partiesGovernmental accounting standards require that all potential component units be evaluated for inclusion in the financial statements of the primary government of the reporting entity. USNH’s policy on ‘Foundations Established for the Benefit of USNH or its Component Institutions’ states that the USNH Board of Trustees retains control over the activities of any affiliated foundation. The USNH policy further states that USNH has the legal authority to terminate the existence of any affiliated foundation, at which time ownership of the related assets would revert to USNH. Two legally separate affiliated foundations are impacted by this policy and, accordingly, are considered blended component units of USNH. The University of New Hampshire Foundation, Inc. (UNHF) and the Keene Endowment Association (KEA) are collectively referred to in the accompanying financial statements as “affiliated entities.” The associated revenues, expenses, assets, liabilities, deferred inflows, deferred outflows, and net position of UNHF and KEA are fully consolidated with those of the campuses in the accompany-ing financial statements, and all associated inter-entity activity has been eliminated.

UNHF, Inc. was incorporated in 1989 as a not-for-profit, tax-exempt organization. Its purpose is to solicit, collect, invest and disburse funds for the sole benefit of the University of New Hampshire. The University of New Hampshire funds a portion of the operating expenses of UNHF. UNHF is governed by its own Board of Directors, the membership of which includes the President of the University of New Hampshire and up to three other members of the USNH Board of Trustees. UNHF has a separate financial statement audit each year. Condensed financial information for UNHF is included in Note 16. The KEA was organized in 1957 as a separate charitable entity to provide financial assistance to deserving students at Keene State College. Income is distributed at the discretion of the Trustees of KEA.

Basis of accountingThe accompanying financial statements have been prepared in accordance with US generally accepted accounting principles (GAAP) prescribed by the Governmental Accounting Standards Board (GASB) using the economic resources measurement focus and the accrual basis of accounting.

USNH follows the requirements of the “business-type activities” (BTA) model as defined by GASB Statement No. 35, Basic Financial Statements – and Management’s Discussion and Analysis for Public Colleges and Universities. BTAs are defined as those that are financed in whole or in part by fees charged to external parties for goods or services. The Statement requires that resources be classified into the following net position categories, as more fully detailed in Note 14:

Net investment in capital assets: Property and equipment at historical cost or fair value on date of acquisition, net of accumulated depreciation and outstanding princi-pal balances of debt attributable to the acquisition or construction of those assets.

Restricted Nonexpendable: Resources subject to externally imposed stipulations that they be maintained permanently by USNH. These funds include the historical gift value of restricted true endowment funds.

Restricted Expendable: Resources whose use by USNH is subject to externally imposed stipulations. Such funds include the accumulated net gains on donor-

restricted “true” endowment funds; the fair value of restricted funds functioning asendowment; restricted funds loaned to students; restricted gifts and endowment income; and other similarly restricted funds.

Unrestricted: Resources that are not subject to externally imposed stipulations. Substantially all unrestricted net position funds are designated to support academic, research, or auxiliary enterprises; invested to function as endowment; or committed to capital construction projects.

The preparation of financial statements in conformity with GAAP requires manage-ment to make estimates and assumptions that affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities at the dates of the financial statements, and the reported amounts of revenues and expenses during the reporting periods. Actual results could differ from these estimates. The most significant areas that require management estimates relate to valuation of certain investments and derivative instruments, useful life and related depreciation of capital assets, and accruals for postretirement medical and other employee-related benefits.

Investments are maintained with established financial institutions whose credit is evaluated by management and the respective governing boards of USNH and its affiliated entities. Investments of operating cash in money market and other mutual funds are generally recorded as cash equivalents. These amounts are invested for purposes of satisfying current operating liabilities and generating investment income to support ongoing operations. Short-term investments represent highly liquid amounts held for other current liabilities.

Property and equipment are recorded at original cost for purchased assets or at fair value on the date of donation in the case of gifts. Equipment with a unit cost of $5,000 or more is capitalized. Building improvements with a cost of $50,000 or greater are also capitalized. The value of equipment acquired under capital leases is recorded at the present value of the minimum lease payments at the inception of the lease. Depreciation of property and equipment is calculated on a straight-line basis over the estimated useful lives of the respective assets. The cost of certain research buildings is componentized for the purpose of calculating depreciation. Buildings and improve-ments are depreciated over useful lives ranging from 4 to 50 years. Depreciable lives for equipment range from 3 to 30 years. (See Note 5 for additional information on depreciation.) USNH does not record donated works of art and historical treasures that are held for exhibition, education, research, and public service.

Library collections are recorded as an expense in the period purchased, except for UNH School of Law library collections which are capitalized annually and depreciated over a ten-year period on a straight-line basis.

Deposits and unearned revenue consist of amounts billed or received in advance of USNH providing goods or services. Advances from the U.S. Government for Federal Perkins Loans to students are reported as government advances refundable. Federal Direct Loan proceeds are posted to student accounts as approved and drawn weekly.

Operating revenues include tuition and fees, grants and contracts, sales of auxiliary services, and other operating revenues. Tuition and fee revenues are reported net of student financial aid discounts and allowances. Operating expenses include employee compensation and benefits, supplies and services, utilities, and depreciation. Operating expenses also include early retirement and other separation incentive stipends and benefits promised to certain employees in exchange for termination of employment. All such termination benefits are accrued as of the date the termination agreements are signed and are presented at net present value at year end. The operating expenses also included the use of federal Cares Act for Higher Education Emergency Relief Fund and the State of New Hampshire Governor’s Office for Emergency Relief and Recovery awards. Nonoperating revenues (expenses) include all other revenues and expensesexcept certain changes in long-term plant, endowment and other net position


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funds, which are reported as other changes in net position. Operating revenues are recognized when earned and expenses are recorded when incurred. Restricted grant revenue is recognized only to the extent of applicable expenses incurred or, in the case of fixed-price contracts, when the contract terms are met or completed.

Unconditional pledges of nonendowment gifts are presented net of estimated amounts deemed uncollectible after discounting to the present value of expected future cash flows. Because of uncertainties regarding their realization and valuation, bequest intentions and other conditional promises are not recognized as assets until the specified conditions are met. In accordance with GASB requirements, endowment pledges expected to be received over the next ten years, totaling $10,563,000 and $7,317,000 at June 30, 2021 and 2020, respectively, have not been reported in the accompanying financial statements. USNH generally uses restricted funds first when an expense is incurred where both restricted and unrestricted funds are available.

Endowment return used for operations per application of the Board-approved endowment spending policy is reported as nonoperating revenue. Net realized and unrealized gains/losses and interest/dividend income earned on endowment and similar investments, together with the excess (deficiency) of these earnings over the return used for operations, are reported as other changes in net position.

The System’s financial statements include comparative financial information. Certain prior year amounts have been reclassified to conform to the current year presentation.

New reporting standardsThe System’s financial statements and notes for fiscal years 2021 and 2020 as presented herein reflect the adoption of the following three GASB Statements for the year ended June 30, 2021. The adoption of these standards did not have a material effect on the financial statements, and no restatement of prior year balances was made.

GASB No. 84: Fiduciary Activities. The objective of this standard is to improve guidance regarding the identification of fiduciary activities for accounting and financial reporting purposes and how those activities should be reported.

GASB No. 89: Accounting for Interest Cost Incurred before the End of a Construction Period; The objectives of this standard are (1) to enhance the relevance and comparability of information about capital assets and the cost of borrowing for a reporting period and (2) to simplify accounting for interest cost incurred before the end of a construction period.

GASB No. 97: Certain Component Unit Criteria, and Accounting and Financial Reporting for Internal Revenue Code Section 457 Deferred Compensation Plans; The objectives of

this standard are to (1) increase consistency and comparability related to the reporting of fiduciary component units in circumstances in which a potential component unit does not have a governing board and the primary government performs the duties that a governing board typically would perform; (2) mitigate costs associated with the reporting of certain defined contribution pension plans, defined contribution other postemploy-ment benefit (OPEB) plans, and employee benefit plans other than pension plans or OPEB plans (other employee benefit plans) as fiduciary component units in fiduciary fund financial statements; and (3) enhance the relevance, consistency, and comparability of the accounting and financial reporting for Internal Revenue Code (IRC) Section 457 deferred compensation plans (Section 457 plans) that meet the definition of a pension plan and for benefits provided through those plans.

As allowed under GASB Statement No 95, Postponement of the Effective Dates of Certain Authoritative Guidance, the System postponed by one year the adoption of certain provisions in GASB Statements and Implementation Guides that first became effective or were scheduled to become effective for fiscal year ended June 30, 2020, and later.

2. Cash, cash equivalents and short-term investmentsCash equivalents, and short-term investments are recorded at fair value. USNH’s invest-ment policy and guidelines specify permitted instruments, durations, required ratings and insurance of USNH cash, cash equivalents and short-term investments. The investment policy and guidelines are intended to mitigate credit risk on investments individually and in the aggregate through restrictions on investment type, liquidity, custodian, dollar level, maturity, and rating category. Money market funds are placed with the largest national fund managers. These funds must be rated AA/Aa by Standard & Poor’s and Moody’s Investor Service and comply with Securities and Exchange Commission Rule 2A-7. Repur-chase agreements must be fully collateralized at 102% of the face value by US Treasuries, or 103% of the face value by US Government- backed or guaranteed agencies or govern-ment sponsored enterprises. In addition, USNH investments may not exceed 5% of any institution’s total deposits or 20% of any institution’s net equity.

Cash equivalents represent amounts invested to satisfy current operating liabilities and include repurchase agreements, money market funds and other mutual funds. Repurchase agreements are limited to overnight investments only. Short-term invest-ments are highly liquid amounts held to support specific current liabilities. Cash, cash equivalents and short-term investments are generally uninsured and uncollateralized against custodial credit risk, and the related mutual funds are not rated. Cash and cash equivalents totaled $85,670,000 and $65,339,000 at June 30, 2021 and 2020, respective-ly, and short-term investments totaled $130,477,000 and $158,907,000 at June 30, 2021 and 2020, respectively. See Note 4 for additional information on fair value classifications.

The components of cash, cash equivalents and short-term investments are summarized below ($ in thousands):


Cash balance $42,166 $ – $ – $ 42,166 $13,969 $ – $ – $ 13,969 Repurchase agreements – 4,845 4,845 Less than 1 year – 7,166 7,166 Less than 1 year Money market funds 38,659 – 38,659 Less than 1 year 44,204 – 44,204 Less than 1 year Subtotal cash and cash equivalents 42,166 38,659 4,845 85,670 13,969 44,204 7,166 65,339 Money market funds 38,237 – 38,237 Less than 1 year 35,287 – 35,287 Less than 1 year Domestic equity 795 – 795 Less than 1 year 643 – 643 Less than 1 year Mutual Funds 91,407 – 91,407 1-5 years 95,072 – 95,072 1-5 years Corporate bonds – – – – 14,419 14,419 1-5 years US government and agencies – – – – 11,880 11,880 1-5 years Municipal bonds – – – – 1,573 1,573 1-5 years Convertible note – 38 38 1-5 years – 33 33 1-5 years Subtotal short-term investments – 130,439 38 130,477 – 131,002 27,905 158,907 Total cash, cash equivalents and short-term investments $42,166 $169,098 $4,883 $216,147 $13,969 $175,206 $35,071 $224,246

Cash Level 1 Level 2

TotalWeighted Average Maturity

Cash Equivalents and Short-Term Investments Cash

Level 1 Level 2Total

Weighted Average Maturity

Cash Equivalents and Short-Term Investments

Balance and Terms as of June 30, 2021 Balance and Terms as of June 30, 2020

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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be Reproduced 3. Accounts, pledges, and notes receivable

Accounts receivable at June 30 consisted of the following ($ in thousands):

2021 2020

Grants and contracts $22,983 $25,117 Student and general 7,530 8,988 State of NH capital projects – 30 Allowance for doubtful accounts (3,476) (2,837) Total accounts receivable, net $27,037 $31,298

Pledges receivable at June 30 consisted entirely of unconditional nonendowment promises to pay as follows ($ in thousands):

2021 2020

Pledges receivable $ 10,919 $ 8,651 Discounts and allowance for doubtful pledges (1,239) (2,178) Total pledges receivable, net 9,680 6,473 Less: noncurrent portion (7,131) (3,936) Current portion $ 2,549 $ 2,537

Notes receivable at June 30 consisted primarily of student loan funds as follows ($ in thousands):

2021 2020

Perkins loans $10,067 $13,528 Other loans, restricted and unrestricted 1,348 1,031 Allowance for doubtful loans (1,350) (1,419) Total notes receivable, net 10,065 13,140 Less: noncurrent portion (8,323) (11,070) Current portion $ 1,742 $ 2,070

4. InvestmentsUSNH’s investment policy and guidelines specify permitted instruments, duration and required ratings for pooled endowment funds. The policy and guidelines are intended to mitigate risk on investments individually and in the aggregate while maximizing total returns and supporting intergenerational equity of spending levels. Illiquid investments are limited to 20% of the USNH consolidated endowment pool. Credit risk is mitigated by due diligence in the selection and continuing review of investment managers as well as diversification of both investment managers and underlying investments. Except in unusual circumstances, no more than 15% of total portfolio assets may be invested in any one actively managed strategy. If an invest-ment manager is retained to manage more than one strategy, that manager will be limited to 20% of total portfolio assets. Passively managed investment strategies will not be limited within the portfolio; however, any one manager of passive strategies will be limited to 20% of total portfolio assets. Any manager positions exceeding these limits will be reviewed by the Finance Committee for Investments and this committee will decide the appropriate course of action to bring active manager exposures back in line with the concentration limit. Private global equity investments are limited to 20% of the endowment pool. No USNH endowment investments were denominated in foreign currencies as of June 30, 2021or June 30, 2020.

GASB Statement No. 72, Fair Value Measurement and Application, requires that USNH categorize assets measured at fair value using a three-tiered hierarchy based on the valuation methodologies employed. The hierarchy includes the following:

Level 1 — Value based on quoted prices (unadjusted) in active markets for identical assets that are accessible at the measurement date

Level 2 — Value based on inputs other than quoted prices that are observable for an asset either directly or indirectly; and

Level 3 — Value based on unobservable inputs for an asset

In determining fair value of investment assets, USNH utilizes valuation techniques that maximize the use of observable inputs and minimize the use of unobservable inputs to the extent possible. As a practical expedient to estimate the fair value of USNH’s interests, certain investments in commingled funds and limited partnerships are reported at the net asset value (NAV) determined by the respective fund managers, without adjustment when assessed as reasonable by USNH, unless it is probable that all or a portion of the investment will be sold for an amount different from NAV. Because these investments are not readily marketable, their estimated fair values may differ from the values that would have been assigned had a ready market for such investments existed, and such differences could be material. As of June 30, 2021, and 2020, USNH had no plans or intentions to sell such investments at amounts different from NAV. Investments reported at NAV as a practical expedient are not categorized in the fair value hierarchy.

The endowment and similar investment holdings of the campuses and affiliated entities as of June 30, 2021and 2020, respectively, are summarized below ($ in thousands):

Campuses Affiliated Entities

2021 2020 2021 2020

Pooled endowments: Campuses $662,606 $533,687 $ – $ – UNH Foundation – – 296,533 235,797 Keene Endowment Association – – 17,022 13,585 Life income and annuity funds 98 81 5,263 4,144 Funds held in trust 19,725 15,625 – – Total $682,429 $549,393 $318,818 $253,526

The majority of USNH’s investments are units of institutional commingled funds and limited partnerships invested in equity, fixed income, hedge, natural resources, private equity, or real estate strategies. Hedge strategies involve funds whose managers have the authority to invest in various asset classes at their discretion, including the ability to invest long and short. Funds with hedge strategies generally hold securities or other financial instruments for which a ready market exists and may include stocks, bonds, put or call options, swaps, currency hedges and other instruments which are valued by the investment manager. To the extent quoted prices exist the manager would use those; when these are not available, other methodologies maximizing observable inputs would be used for the valuation, such as discounted cash flow analysis, capitalization of current or stabilized net operating income, replacement costs, or sales contracts and recent sales comparable in the market. Private equity funds employ buyout, growth, venture capital, and distressed security strategies. Real asset funds generally hold interests in private real estate. Fixed income securities had maturities up to 7 years and 15 years at June 30, 2021 and 2020, respectively, and carried ratings ranging from AAA to Baa3 as of June 30, 2021 and 2020. The mutual fund investments held in the endowment pools are not rated.


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be ReproducedThe following table summarizes the fair value of USNH’s investments by type ordered alphabetically ($ in thousands):

As of June 30, 2021, USNH had one equity hedge fund and one global fixed income fund in a lock-up period set to expire in nine months. As of June 30, 2021, UNHF had one year lock up periods for three of its funds, one global equity and two of its hedge funds. Fixed income, private equity and real estate funds classified as illiquid have no ability to be redeemed at this time. For USNH, of the 36 funds classified as illiquid, eleven are currently in liquidation; one is expected to start liquidation within the next year; eighteen are expected to start liquidation in 2 to 15 years, and six currently have no expected liquidation dates. For UNHF, 16funds are classified as illiquid and are expected to be liquidated over the next one to 10 years.

As of June 30, 2021 and 2020, USNH has one outstanding investment liquidation request which has been limited by the respective fund managers. USNH’s estimated fair values of these investments at June 30, 2021 and 2020 are $50,000 and $63,000, respectively. It is uncertain when, or if, the funds will be fully collected at the NAV recorded.

Unfunded commitments with various private equity and similar alternative investment funds totaled $42,366,000 for USNH and $17,901,000 for UNHF at June 30, 2021. This compares to $44,251,000 and $22,749,000, respectively, at June 30, 2020.

Balances as of June 30, 2021 Balances as of June 30, 2020

Endowment and similar investments – campuses

Domestic equity $137,688 $ – $ – $105,340 $ 243,028 $ 117,869 $ – $ – $ 72,443 $190,312 Global equity – – – 10,851 10,851 – – – – – Global fixed income 62,876 – – – 62,876 54,321 – – – 54,321 Hedge funds: Distressed/Restructuring – – – 21,319 21,319 – – – 18,297 18,297 Equity Hedge – – – 43,887 43,887 – – – 33,365 33,365 Event-Driven – – – 70,436 70,436 – – – 61,501 61,501 Fund of Funds – – – 2,009 2,009 – – – 5,755 5,755 Inflation hedging assets 12,784 – – 12,671 25,455 8,090 – – 9,523 17,613 International equity 23,994 – – 62,684 86,678 21,330 – – 53,440 74,770 Money market 27,188 – – – 27,188 36,012 – – – 36,012 Private equity & non-marketable real assets – – – 68,977 68,977 – – – 41,822 41,822 Trust funds – 19,725 – – 19,725 – 15,625 – – 15,625 Total endowment and similar investments – campuses $264,530 $ 19,725 $ – $398,174 $ 682,429 $ 237,622 $15,625 $ – $296,146 $549,393

Endowment and similar investments – affiliated entities

Domestic equity $ 19,815 $ – $ – $ 59,346 $ 79,161 $ 18,629 $ – $ – $ 44,044 $ 62,673 Global equity 569 – – 26,760 27,329 562 – – 5,791 6,353 Global fixed income 16,771 3,017 4,292 – 24,080 15,317 1,915 4,242 1,089 22,563 Hedge funds: Distressed/Restructuring – – – 39,918 39,918 – – – 39,546 39,546 Diversified – – – 7,251 7,251 – – – 4,900 4,900 Equity Hedge – – – 30,549 30,549 – – – 21,612 21,612 Inflation hedging assets 4,311 6,313 – – 10,624 3,611 6,691 – – 10,302 International equity 9,825 – – 44,043 53,868 16,572 – – 32,754 49,326 Money market 12,399 – – – 12,399 10,921 – – – 10,921 Private equity & non-marketable real assets – – – 33,639 33,639 – – – 25,330 25,330 Total endowment and similar investments – affiliated entities $ 63,690 $ 9,330 $4,292 $241,506 $ 318,818 $ 65,612 $ 8,606 $ 4,242 $ 175,066 $253,526

Total endowment and similar investments $328,220 $ 29,055 $4,292 $639,680 $1,001,247 $ 303,234 $ 24,231 $ 4,242 $ 471,212 $802,919

Investments Classified in Fair Value Hierarchy

Level 1 Level 2 Level 3

Investments Measured

at NAV Total

Investments Classified in Fair Value Hierarchy

Level 1 Level 2 Level 3

Investments Measured

at NAV Total


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Liquidity Terms as of June 30, 2021 Redemption

Daily Monthly Quarterly Semi-Annual Annual illiquid Total Notice Period Endowment and similar investments – campusesMoney market $ 27,188 $ – $ – $ – $ – $ – $ 27,188 DailyGlobal fixed income 62,876 – – – – – 62,876 DailyInternational equity 23,994 62,684 – – – – 86,678 1-10 daysInflation hedging assets 12,784 12,671 – – – – 25,455 1-15 days Domestic equity 137,688 – 105,340 – – – 243,028 1- 60 daysGlobal equity – – 10,851 – – – 10,851 30 days Hedge funds: Equity Hedge – – 43,541 – 346 – 43,887 60 days Event-Driven – – 29,286 41,150 – – 70,436 60-90 days Distressed/Restructuring – – – – 21,319 – 21,319 90 days Fund of Funds – – – – – 2,009 2,009 illiquid Private equity & non-marketable real assets – – – – – 68,977 68,977 illiquid Funds held in trust – – – – – 19,725 19,725 illiquidTotal endowment and similar investments – campuses $264,530 $ 75,355 $ 189,018 $ 41,150 $21,665 $ 90,711 $ 682,429

Endowment and similar investments – affiliated entitiesMoney market $ 12,399 $ – $ – $ – $ – $ – $ 12,399 DailyInflation hedging assets 10,624 – – – – – 10,624 Daily Global fixed income 19,789 – – – 4,228 63 24,080 Daily, illiquidGlobal equity 7,042 – 20,287 – – – 27,329 1-30 days Domestic equity 27,227 7,812 44,122 – – – 79,161 1-60 daysInternational equity 27,988 22,381 3,499 – – – 53,868 1-90 daysHedge funds: Equity Hedge – – 30,549 – – – 30,549 30-90 days Diversified – – – 4,638 2,613 – 7,251 60 days Distressed/Restructuring – – 9,331 12,464 18,123 – 39,918 60-90 daysPrivate equity & non-marketable real assets – – – – – 33,639 33,639 iIlliquidTotal endowment and similar investments - affiliated entities $105,069 $ 30,193 $ 107,788 $ 17,102 $24,964 $ 33,702 $ 318,818

Total endowment and similar investments $369,599 $105,548 $ 296,806 $ 58,252 $46,629 $124,413 $1,001,247

Investment liquidity for the past two years is aggregated below based on redemption terms or availability ($ in thousands):

Liquidity Terms as of June 30, 2020 Redemption

Daily Monthly Quarterly Semi-Annual Annual illiquid Total Notice Period Endowment and similar investments – campusesMoney market $ 36,012 $ – $ – $ – $ – $ – $ 36,012 DailyGlobal fixed income 54,321 – – – – – 54,321 DailyInternational equity 21,330 53,440 – – – – 74,770 1-10 days Inflation hedging assets 8,090 9,523 – – – – 17,613 1-15 daysDomestic equity 117,869 – 72,443 – – – 190,312 1- 60 daysHedge funds: Equity Hedge – – 32,908 – 457 – 33,365 60 days Event-Driven – – 24,867 36,634 – – 61,501 60-90 days Distressed/Restructuring – – – – 18,297 – 18,297 90 days Fund of Funds – – – – – 5,755 5,755 illiquid Private equity & non-marketable real assets – – – – – 41,822 41,822 illiquidFunds held in trust – – – – – 15,625 15,625 illiquidTotal endowment and similar investments – campuses $237,622 $62,963 $ 130,218 $36,634 $18,754 $ 63,202 $ 549,393

Endowment and similar investments – affiliated entitiesMoney market $ 10,921 $ – $ – $ – $ – $ – $ 10,921 DailyInflation hedging assets 10,302 – – – – – 10,302 Daily Global fixed income 17,232 1,089 – – 1,540 2,702 22,563 Daily, illiquidGlobal equity 562 – 5,791 – – – 6,353 1-30 daysDomestic equity 23,667 5,000 34,006 – – – 62,673 1-60 daysInternational equity 30,052 16,859 2,415 – – – 49,326 1-90 daysHedge funds: Equity Hedge – – 21,612 – – – 21,612 30-90 days Diversified – – – 4,804 96 – 4,900 60 days Distressed/Restructuring – – 7,580 10,487 21,479 – 39,546 60-90 daysPrivate equity & non-marketable real assets – – – – – 25,330 25,330 iIlliquidTotal endowment and similar investments - affiliated entities $ 92,736 $22,948 $ 71,404 $15,291 $23,115 $ 28,032 $ 253,526

Total endowment and similar investments $330,358 $85,911 $ 201,622 $51,925 $41,869 $ 91,234 $802,919


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be Reproduced5. Property and equipment

Property and equipment activity for the years ended June 30, 2021 and 2020 is summarized as follows ($ in thousands):

Land $ 15,626 $ 1,508 $ 828 $ 17,962 $ – $ (2,706) $ 15,256 Buildings and improvements 1,834,273 38,948 (14,351) 1,858,870 49,096 (7,721) 1,900,245 Equipment 140,811 20,556 (9,041) 152,326 10,259 (1,929) 160,656 Construction in progress, net 52,820 53,789 (40,457) 66,152 43,208 (49,096) 60,264 Total property and equipment 2,043,530 114,801 (63,021) 2,095,310 102,563 (61,452) 2,136,421 Less: accumulated depreciation (926,169) (68,831) 19,615 (975,385) (68,861) 9,265 (1,034,981) Property and equipment, net $1,117,361 $ 45,970 $ (43,406) $1,119,925 $ 33,702 $(52,187) $1,101,440

Contractual obligations for major construction projects totaled approximately $66,042,000 and $50,014,000 at June 30, 2021 and 2020, respectively.

6. Accrued employee benefitsAccrued employee benefit obligations at June 30 are summarized below ($ in thousands):

BalanceJune 30, 2019 Additions

Retirements& Changes

BalanceJune 30, 2020 Additions

Retirements& Changes

BalanceJune 30, 2021

2020 2021

Additional retirement contribution $ 2,171 $ (217) $ 105 $ 2,059 $ (865) $ 632 $ 1,826 $ 865 Standard employee separation incentives 2,267 (1,447) 1,284 2,104 (896) 526 1,734 1,392 Enhanced retirement and separation programs – – – – (15,789) 56,086 40,297 29,455 Long-term disability 2,044 (455) 443 2,032 (429) (122) 1,481 429 Workers’ compensation 3,223 (952) 600 2,871 (878) 850 2,843 878 Compensated absences 20,763 (2,074) 2,168 20,857 (5,102) 6,563 22,318 3,719 Other benefits 994 – 223 1,217 – (328) 889 724 Total accrued employee benefits $31,462 $(5,145) $ 4,823 $31,140 $(23,959) $64,207 $71,388 $37,462


Payments to/on Behalf ofParticipants

Expenses& OtherChanges


Payments to/on Behalf ofParticipants

Expenses& OtherChanges


CurrentPortion

2020 2021

USNH had designated cash assets to fully fund the Additional Retirement Contribution obligations at June 30, 2021 and 2020. These assets are not admin-istrated through a trust. The Additional Retirement Contribution program is not available to employees hired after June 30, 2011. Eligible employees hired after June 30, 2011 may elect to participate in USNH’s defined contribution retirement plans administered by others. Retirement contributions by USNH for employees enrolled in the defined contribution plans range from 4% to 10% of eligible salaries for enrolled participants. USNH additions to the defined contribution plans totaled $27,291,000 and $28,385,000 in 2021 and 2020, respectively. Retirement contributions by plan members totaled $29,289,000 and $28,183,000 in 2021 and 2020, respectively.

Early retirement and employee separation incentive programs were provided to various faculty and staff during 2021and 2020. Such incentives include stipends, as well as medical, educational, and other termination benefits. The future cost asso-ciated with these incentive options is accrued as of the date of acceptance into the program. The liability balances of $1,734,000 and $2,104,000 at June 30, 2021and 2020 represent obligations for 28 and 66 participants, respectively, which will be remitted in fiscal years 2022 through 2025.

USNH Board of Trustees approved voluntary separation incentive programs for reduction of force for 2021. Such incentives include salary continuation, year of service stipends, and medical benefits. The future cost associated with these incentive options is accrued as of the date of acceptance into the program, which was $56,086,000 in FY21. The liability balance of $40,297,000 at June 30, 2021,represents obligations for 484 participants, which will be remitted in fiscal years 2022 through 2027.

The Additional Retirement Contribution program is a single employer plan administered by USNH and offered to eligible employees hired between July 1, 1994 and June 30, 2011. Under this plan, staff meeting certain voluntary defined benefit plan contribution levels receive an additional 1% of their salary contributed to their defined contribution retirement plan (see below) by USNH in lieu of postretirement medical benefits. Employees meeting certain service guidelines prior to July 1, 1994 are also eligible for a guaranteed minimum employer retirement contribution of $10,000 plus an additional $1,000 for each year of service in excess of 20 less 1% of the participant’s salary account. There were 155 and 295 active employees meeting the requirements for the guaranteed minimum employer contribution as of June 30, 2021 and 2020, respectively.

The calculations for the Additional Retirement Contribution program are based on the benefits provided by the program at the time of the last biennial actuarial valua-tion, December 31, 2019, and were developed using the Entry Age Normal Actuarial Cost Method. The discount rate used in determining the accrued liabilities was 2.12% and 2.74% for 2021 and 2020, respectively, based on Bond Buyer 20-Bond General Obligation index rate as of the measurement date. Inflation rates of 2.5% and salary increase rates of 3% were used to determine the liability along with the Pub G.H-2010 General Employee Headcount-weighted Mortality Table projected generationally with Scale MP-2019. USNH accrued $1,826,000 and $2,059,000 at June 30, 2021 and 2020, respectively, for the related obligations. If the discount rate were to increase by 1%, the total liability at June 30, 2021 would be $1,768,000. Similarly, if the discount rate were to decrease by 1%, the total liability at June 30, 2021 would be $1,885,000. The Additional Retirement Contribution program expense was ($102,000) and ($55,000) for fiscal years 2021 and 2020, respectively.


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USNH sponsors other benefit programs for its employees, including long-term disability, workers’ compensation, and compensated absences. Long-term disability payments are provided through an independent insurer. The associated medical benefits are accrued and paid by USNH until age 65, at which point the postretire-ment medical plan takes over, if applicable. Workers’ compensation accruals include amounts for medical costs and annual stipends. A small number of chronic workers’ compensation cases will require stipends and regular employee medical benefits for life. Coverage for such claims is provided through an independent insurer. USNH also accrues amounts for compensated absences as earned. These accrued balances at June 30 represent vacation and earned time amounts payable to employees upon termination of employment.

USNH is self-insured for a portion of certain risks, including workers’ compensation, employee long-term disability, and certain student health insurance claims. Most employee and retiree medical and dental coverage provided by USNH is also self-insured. The costs of self-insured medical and dental claims and administrative fees totaled $66,657,000 and $66,106,000 for fiscal year 2021 and 2020, respectively. These amounts include $3,811,000 and $4,212,000 for estimated claims incurred but not reported as of June 30, 2021 and 2020, respectively.

In conjunction with the primary medical plan offering for active employees, USNH purchases stop-loss coverage which limits the USNH cost of claims to $500,000 per participant in most cases. The liabilities recorded in the financial statements for all USNH self-insured programs are developed by third party claim administrators and based on historical claims data. Management reviewed the calculations for reason-ableness and believes the liabilities are sufficient to cover the actual claims incurred.

In addition to the benefits accruals included above, USNH created and fully funded a trust to hold assets set aside for its Operating Staff Retirement Plan on June 29, 2017. The related asset and liability values are not included in the financial statements. The related investment balances as of June 30, 2021 and 2020 are summarized below. ($ in thousands):

Trust Investment Components 2021 2020

Cash and equivalents $ 367 $ 206 Fixed income 2,727 2,862 Equities 3,365 2,720 Real assets 90 75 Total including accrued income $6,549 $5,863

The plan has been closed to new participants since 1987. At June 30, 2021 there were approximately 149 current annuitants and 27 participants with deferred bene-fits, all fully vested. This compares to 165 current annuitants and 27 participants with deferred benefits as of June 30, 2020. The determination of total pension liabilities for this program was based on actuarial calculations completed by the plan trustee as of June 30, 2021 and 2020. The calculations were developed using the Entry Age Normal Actuarial Cost Method and the Pub G-2010 Total Dataset with MP-2020 mortality tables. The 2020 valuation used Scale MP-2019. The discount rate used was 5.5% in both years based on the long-term expected rate of return on the related investments. The plan fiduciary net position was $6,549,000 as of June 30, 2021and $5,863,000 as of June 30, 2020 which resulted in the recording of a net pension asset of $1,557,000 and $432,000 for fiscal years 2021 and 2020, respectively. The actuarially determined liability for the program was $4,992,000 as of June 30, 2021 and $5,430,000 as of June 30, 2020. If the discount rate were to increase by 1%, the net pension asset at June 30, 2021 would be $1,897,000. Similarly, if the discount rate were to decrease by 1%, the net pension asset at June 30, 2021 would be $1,168,000. The plan expense was ($212,000) and $129,000 for fiscal years 2021 and 2020, respectively.

7. Postretirement medical benefitsThe primary defined benefit postretirement medical plan has two components. The first offering known as the Medicare Complementary Plan (MCP), was optional for full-time status employees hired before July 1, 1994 and not offered to new employees after that date. At December 31, 2020 and 2019, respectively, there were 942 and 943 former employees receiving benefits under this program along with their eligible dependents. As of December 31, 2020 and 2019, there were 107 and 133 active employees, respectively, who along with their dependents, may eventually be eligible to receive benefits under this program. The MCP provides limited medical coverage for the remaining life of the participants. There are no costs to participate in the plan, but retirees must pay a portion of the actual costs of services rendered.

Employees hired on July 1, 1994 or later are eligible for the current offering which provides bridge coverage only for retirees aged 62-65. Retired employees must have reached age 62, completed at least 10 years of benefits eligible service, participated in the active retirement plans during their last 10 years of bene-fits-eligible service, and participated in USNH’s active medical plan at the time of retirement in order to be eligible for the plan. Retirees contribute to the plan at then-current employee medical rates during the bridge period. As of December 31, 2020 and 2019, respectively, there were 97 and 68 retirees receiving benefits under this program along with their dependents. As of December 31, 2020 and 2019, respectively, there were also 3,415 and 3,563 active employees who, along with their dependents, may eventually be eligible to receive benefits under this program. The primary postretirement medical plan holds no assets. Together, the above offerings constitute the primary postretirement medical plan. This is an Other Post-Employment Benefits (OPEB) single-employer plan and funded on a pay-as-you-go basis with benefits paid when due.

Third-party actuaries are used to determine the postretirement benefit obligation and annual expense amounts. Actuarial calculations reflect a long-term perspective. Such calculations involve estimates and, by definition, are subject to revision. The healthcare cost trend and discount rate assumptions have a significant effect on the amounts reported.

The components of postretirement medical liability as of June 30, 2021 and 2020 were as follows ($ in thousands):

Postretirement Medical Plan Liability 2021 2020

Service costs $ 1,143 $ 1,247 Interest 2,444 3,339 Benefit payments (4,795) (5,085) Change of benefit terms (9,533) (318) Differences between expected and actual experience (999) 850 Changes in assumptions 7,336 7,664 Net change (4,404) 7,697 Liability at beginning of year 90,441 82,744 Liability at end of year $86,037 $90,441 Current portion $ 5,342 $ 4,412


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Draft 6-14-22 For Discussion Purposes Only Subject to Change Not to be ReproducedThe total postretirement benefit obligation is measured at December 31, 2020 for the June 30, 2021 financial statements based on the last biennial actuarial valuation,

December 31, 2019, developed using the Entry Age Normal Actuarial Cost Method and the Pub T.H-2010 mortality tables with Scale MP-2019. A roll forward calculation was performed for the December 31, 2020 measurement date based on the biennial actuarial valuation to calculate postretirement benefit obligation for the June 30, 2021 finan-cial statements using the Entry Age Normal Cost Method and the Pub T.H-2010 Teacher Employee Headcount-weighted Mortality Table projected generationally with Scale MP-2019. For measurement purposes the 2021 and 2020 initial rate of increase in the cost of healthcare services was assumed to be 6.5% for participants, reduced by 0.25% each year thereafter until reaching an ultimate rate of 4.5% per year. The initial increase in the cost of prescriptions was assumed to be 8.5%, reduced by 0.25% each year thereafter until reaching an ultimate rate of 4.5% per year. Salary increases of 3.0% were included in the calculations for fiscal year 2021 and 2020. A single discount rate of 2.12% and 2.74% was used based on the Bond Buyer 20-Bond General Obligation index rate as of December 31, 2020 and 2019, respectively. The actuarially determined postretirement medical expense for the plan for the years ended June 30, 2021 and 2020 were ($5,108,000) and $4,237,000, respectively.

The following presents the sensitivity of the postretirement medical plan liability to changes in the discount rate and healthcare cost trend rates ($ in thousands):

USNH also accrued $102,000 as of June 30, 2021 and 2020, for potential obligations related to postretirement care of certain USNH police personnel. The USNH Board of Trustees holds the authority to change these benefit plans at any time. Further information on the Additional Retirement Contribution, Operating Staff Retirement Plan, and Postretirement Medical Plan can be found in the Required Supplemental Information on page 50 of the publication.

8. Long-term debtUSNH long-term debt activity, exclusive of deferred losses or gains on refunding, for the years ended June 30, 2021 and 2020 is summarized below ($ in thousands):

NHHEFA bonds Series 2005A $ 46,250 $ – $ (1,850) $ 44,400 $ – $ (2,100) $ 42,300 $ 2,000 Series 2005B 64,360 – (4,760) 59,600 – (4,905) 54,695 5,075 Series 2011A 6,000 – – 6,000 – – 6,000 6,000 Series 2011B 30,260 – (2,110) 28,150 – (2,210) 25,940 2,310 Series 2012 6,470 – (3,170) 3,300 – (3,300) – – Series 2014 13,595 – (2,155) 11,440 – (2,200) 9,240 2,240 Series 2015 110,530 – (2,855) 107,675 – (2,990) 104,685 3,115 Series 2016 49,825 – (2,515) 47,310 – (2,640) 44,670 2,780 Series 2017A 53,805 – (1,760) 52,045 – (1,850) 50,195 1,940 Series 2017B 47,920 – (1,950) 45,970 – (1,990) 43,980 2,030 Unamortized discounts/premiums, net 28,404 – (1,938) 26,466 – (1,915) 24,551 1,915 Capital leases 7,800 – (1,163) 6,637 – (1,215) 5,422 1,270 Total bonds and leases $465,219 $ – $(26,226) $438,993 $ – $(27,315) $411,678 $30,675


Additions& OtherChanges Retirements




CurrentPortion

2020 2021

OPEB Liability as of December 31, 2020

OPEB Liability as of December 31, 2019

Sensitivity to change in discount rate 1% increase Current rate 1% decrease $78,204 $86,037 $ 95,242

$82,273 $90,441 $100,037

Sensitivity to change in health care costs 1% increase Current rate 1% decrease $95,556 $86,037 $77,926

$99,444 $90,441 $82,734

New Hampshire Health and Education Facilities Authority (NHHEFA) Bonds NHHEFA is a public body corporate and an agency of the State of New Hampshire whose primary purpose is to assist New Hampshire not-for-profit educational and health care institutions in the construction and financing (or refinancing) of related facilities. NHHEFA achieves this purpose primarily through the issuance of bonds. Since 1989 all USNH bonds have been issued through NHHEFA. None of USNH’s NHHEFA bonds provide for a lien or mortgage on any property. USNH is obligated under the terms of the NHHEFA bonds to make payments from revenues received from certain housing, dining, student union, recreational, and other related revenue generating facilities financed by the bonds. The state is not liable for the payment of principal or interest on the NHHEFA bonds, nor is the state directly, indirectly or contingently obligated to levy or pledge any form of taxation whatsoever or to make any appropriation for their payment. USNH Bond indentures have a provision that in an event of default resulting from a payment default by USNH the principal may be accelerated and become immediately due and payable, at par, with interest payable thereon to the accelerated payment date. USNH is in compliance with all covenants specified in the NHHEFA bond, as well as capital lease agreements, the most restrictive of which is maintenance of a debt-service coverage ratio, as defined, of at least 1.0 to 1.0.


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USNH’s bond portfolio at June 30, 2021 consisted of fixed rate and variable rate issues. The variable rate demand bonds (Series 2005A, 2005B, 2011B) are fully hedged via interest rate swap agreements (see Note 9 below), with all three issues supported by standby bond purchase agreements as of June 30, 2021 and 2020. The variable interest rates for the Series 2005A and 2005B Bonds at June 30, 2021 and 2020 were 0.02% and 0.13%, respectively. The 2011B Bonds variable interest rates at June 30, 2021 and 2020 were 0.01% and 0.14%, respectively.

Maturity dates and interest terms of outstanding debt issues are summarized below:

NHHEFA Bonds Maturity Date Interest Terms and Rates Series 2005A 7/1/2035 Variable with daily pricing

Series 2005B 7/1/2033 Variable with daily pricing Series 2011A 7/1/2021 Fixed at 3.5% Series 2011B 7/1/2033 Variable with daily pricing

Series 2014 7/1/2024 Fixed at 2.1% Series 2015 7/1/2045 Fixed at 3.8% Series 2016 7/1/2046 Fixed at 2.7%

Series 2017A 7/1/2037 Fixed at 3.1%Series 2017B 7/1/2037 Fixed at 3.4%

Capital leasesOn April 30, 2004, USNH entered into a capital lease agreement in the amount of $18,292,000 to finance a portion of the costs of equipment housed in UNH’s utility cogeneration facility. The related lease payments are due quarterly through June 2025, including principal as well as interest at a fixed rate of 4.5%. The carrying value of the related assets was $3,913,000 and $4,777,000 as of June 30, 2021 and 2020, respectively.

State of NH general obligation bondsThe state, through acts of its legislature, provides funding for certain major plant facil-ities on USNH campuses. The state obtains its funds for these construction projects

from general obligation bonds, which it issues from time to time. Debt service is funded by the general fund of the state, which is in the custody of the State Treasurer. The state is responsible for all repayments of these bonds in accordance with bond indentures. USNH facilities are not pledged as collateral for these bonds and creditors have no recourse to USNH. Accordingly, the state’s debt obligation attributable to USNH’s educational and general facilities is not reported as debt of USNH. As construction expenditures are incurred by USNH on state-funded educa-tional and general facilities, amounts are billed to the state and recorded as State of New Hampshire capital appropriations.

Maturity of long-term debt obligationsUSNH long-term debt obligations are scheduled to mature as follows using the associated fixed, estimated synthetic fixed, and expected variable rates in effect as of June 30, 2021 over the remaining terms of the individual issuances ($ in thousands):

Fiscal Year Principal Interest Total

2022 $ 28,760 $ 15,320 $ 44,080 2023 23,902 14,277 38,179 2024 24,598 13,350 37,948 2025 25,675 12,381 38,056 2026 18,986 11,472 30,458

2027-2031 95,106 45,916 141,022 2032-2036 99,785 25,571 125,356 2037-2041 40,555 9,870 50,425 2042-2046 28,065 3,528 31,593 2047 1,695 26 1,721 Plus: unamortized discounts/premiums, net 24,551 – 24,551 Total $411,678 $151,711 $563,389

Other long-term obligationsIn addition to the long-term debt presented above, postretirement medical benefits liability in Note 7 and employment benefits liabilities in Note 6, USNH had the following changes in other long-term obligations (in thousands):

*The current portion of these obligations is reported under accounts payable and accrued expenses.

9. Derivative instruments – interest rate swapsUSNH uses hedging derivatives to artificially fix interest rates on variable rate bonds outstanding. The terms and fair market value of swap contracts in place as of June 30, 2021 and 2020 were as follows ($ in thousands):

Asset retirement and other obligations* $ 6,100 $5,575 $ (746) $10,929 $ 11,522 $ (267) $22,184 $8,337 Refundable government advances 17,513 (575) (3,709) 13,229 258 (2,772) 10,715 – Total other long-term obligations $23,613 $5,000 $(4,455) $24,158 $ 11,780 $(3,039) $32,899 $8,337






CurrentPortion

2020 2021

Series 2005A swap October 29, 2008 July 1, 2035 3.6% 67% LIBOR $ 42,300 $ 44,400 $ (9,284) $ (12,003) Series 2005B swap August 1, 2005 July 1, 2033 3.1% 63% LIBOR+0.29% 54,695 59,600 (7,113) (9,688) Series 2011B swap July 1, 2011 July 1, 2033 4.5% 67% LIBOR 25,940 28,150 (5,883) (7,571)

Total $122,935 $132,150 $ (22,280) $(29,262)

EffectiveDate

TerminationDate

PayableFixed Swap

Rate

ReceivableVariable

Swap Rate

Notional Amountat June 30,

2021 2020

Swap Fair Value at June 30,

2021 2020


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Fiscal Year

NotionalBonds

Amortization

EstimatedInterest

Received

Estimated Interest and Fees Paid

Estimated Swap NetOutflows

Termination Risk – This is the risk that the swaps could be terminated as a result of any of several events, which may include rating downgrades below specified levels for USNH or the swap counterparty; covenant violation; swap payment default or bankruptcy by either party; or default events under a bond resolution or trust indenture. Under the terms of each agreement, USNH has the option to terminate a swap at the fair market value at any time by providing notice to the counterparty, while the counterparty may only terminate the swap upon certain termination events. USNH manages termination risk by adhering to bond covenant requirements, employing strategic indicator targets to maintain financial strength, monitoring swap market values and counterparty credit ratings, and diversifying swap counterparties.

Swap Cash Flows – Actual interest payments on the swaps vary as market rates vary.

The table below shows estimated annual future cash flows of the derivative instruments if interest rates remain unchanged from June 30, 2021through the end of each swap contract ($ in thousands):

2022 $ 9,385 $ (212) $ 4,077 $ 3,865 2023 9,975 (191) 3,720 3,529 2024 10,170 (169) 3,355 3,186 2025 10,665 (146) 2,973 2,827 2026 7,250 (133) 2,713 2,580 2027-2031 40,220 (440) 9,350 8,910 2032-2036 35,270 (69) 1,944 1,875 Total $122,935 $(1,360) $28,132 $26,772

6/30/2021 6/30/2020 6/30/2021 6/30/2020 6/30/2021 6/30/2020 Aa2/AA- 0.0% 0.1% 0.1% 0.1% 4.0% 4.1% 4.1% A1/A+ 0.0% 0.1% 0.4% 0.4% 3.2% 3.3% 3.6% A1/BBB+ 0.0% 0.1% 0.1% 0.1% 4.9% 5.0% 5.0%

Interest Rate Paid byUSNH to

Bondholders as of

Interest Rate Received byUSNH from Swap

Counterparties as ofEffective Interest

Rate ThroughAll-in

SyntheticallyFixed Interest

Rate

Counterparty’sMost RecentCredit Rating

Variable Interest Rates Paid and Received Inception-To-Date

Series 2005A swapSeries 2005B swapSeries 2011B swap

Effective interest rates and other key terms of each derivative are described below:

USNH utilizes interest rate swap agreements with counterparties to effectively convert its variable rate debt to fixed rates. The swaps’ fair values and changes therein are recognized in USNH’s financial statements. Differences between the fixed and variable rates in effect at each interest due date are settled net under each swap, increasing or decreasing interest expense. The fair value of the swap instruments is determined using option pricing models that consider interest rates and other market factors, the credit risks of the parties to the agreements, and the estimated benefit or cost to the USNH to cancel the agreements as of the reporting dates. Interest rate volatility, remaining outstanding principal, and time to maturity will affect the swaps’ fair values at subsequent reporting dates. The values were estimated using the zero-coupon discounting method. This method calculates the future payments required by the swap, assuming the current forward rates implied by the yield curve are the market’s best estimate of future spot interest rates. These payments are then discounted using the spot rates implied by the current yield curve for a hypothetical zero-coupon rate bond due on the date of each future net settlement payment. Because the swap fair values are based predominantly on observable inputs corroborated by market data, they are classified in Level 2 of the GASB fair value hierarchy. USNH intends to hold all swap contracts to maturity.

These derivative instruments meet the criteria established by GASB Statement No. 53 for effective hedges as of June 30, 2021 and 2020 and, therefore, their accumulated changes in fair value are reflected as deferrals on the Statements of Net Position (see Note 10). The notional amount of each swap is tied to the outstanding balance of the related bonds throughout the life of the swap. Under the terms of each swap, USNH makes fixed rate interest payments to the counterparty and receives a variable rate payment from the counterparty. USNH makes variable rate payments to bondholders on the related bonds. None of the derivatives require collateralization by USNH at any level of negative fair market value.

Risk DisclosureCounterparty Risk – This is the risk that the counterparty will fail to perform under the terms of the swap agreement. As of June 30, 2021, USNH was exposed to no counterparty credit risk relative to its swaps as all swap market values were negative. The swaps require collateralization of any positive fair value of the swap should the counterparty’s credit rating fall below thresholds identified in the swap contracts. USNH mitigates counterparty risk by spreading the swap exposure among various counterparties, by monitoring bond ratings continuously, and by requiring collateralization in certain circumstances.

Basis Risk – This is the risk of a mismatch between the variable rate received from the swap counterparty and the variable rate paid by USNH to bondholders on the underlying variable rate debt. The effective rate on the debt will vary depending on the magnitude and duration of any basis risk shortfall or surplus. Based on current and historical experience, USNH’s financial advisors expect payments received under the agreements to approximate the related bond payments over the life of the swaps. USNH manages basis risk by closely monitoring daily and monthly rates paid and received on each transaction, by diversifying bond remarketing agents, and by varying swap terms (e.g., 67% of LIBOR vs. 63% of LIBOR +29 bps).


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10. Deferred inflows and outflows of resourcesThe components of Deferred Inflows and Outflows of Resources as of June 30, 2021 and 2020 were as follows ($ in thousands):

2021 2020

Deferred Outflows of Resources Accumulated decrease in fair value of hedging derivatives $22,280 $29,262

Accounting loss on debt refinancing 6,585 7,646 Changes of assumptions: Operating Staff Retirement Plan 29 250 Postretirement Medical Plan 11,891 6,613 Additional Retirement Contribution Program 80 69 Net difference between projected and actual earnings: Operating Staff Retirement Plan 124 168 Difference between expected and actual experience: Postretirement Medical Plan 616 733 Benefit payments subsequent to the measurement date: Postretirement Medical Plan 2,965 2,558 Additional Retirement Contribution Program 675 168 Asset retirement obligations 1,218 1,308 Total Deferred Outflows of Resources $46,463 $48,775

Deferred Inflows of Resources Accounting gain on debt refinancing $ 100 $ 150 Annuities unconditional remainder interest 2,161 1,348 Changes of assumptions: Operating Staff Retirement Plan 15 12 Postretirement Medical Plan 6,192 7,231 Additional Retirement Contribution Program 23 31 Net difference between projected and actual earnings: Operating Staff Retirement Plan 697 44 Difference between expected and actual experience: Operating Staff Retirement Plan 136 145 Postretirement Medical Plan 1,734 1,031 Additional Retirement Contribution Program 288 482 Total Deferred Inflows of Resources $11,346 $10,474

The accumulated decrease in fair value of hedging derivatives is recorded to offset the value of USNH’s interest-rate swap liabilities which qualify for treatment as an effective hedge based on historic interest flows. USNH does not currently expect to terminate any of the swap agreements. The accounting gain on debt refinancing relates to the Series 2012 and 2016 bond issuances while the accounting loss on debt refinancing relates to the Series 2005B, 2011B, 2015 and 2017A bond issuances. These costs will be amortized as a component of interest expense over the remaining terms of the new debt.

Amounts reported as deferred outflows of resources related to benefit payments subsequent to the measurement date will be recognized as a reduction of the respective benefit liability in the year ended June 30, 2021.

Other amounts reported as deferred outflows and inflows of resources which are related to retirement programs will be recognized as a component of pension and OPEB expense over the next seven years as summarized below ($ in thousands):

11. Pass-through grantsUSNH distributed $146,394,000 and $160,788,000 of student loans through the US Department of Education Federal Direct Lending program during 2021 and 2020, respectively. These distributions and related funding sources are not included as expenses and revenues, or cash disbursements and cash receipts, in the accompanying financial statements. The Statements of Net Position include receivables of $103,000 and $182,000 as of June 30, 2021 and 2020, respectively, for direct loans disbursed in excess of US Department of Education receipts.

12. Endowment return used for operationsThe objective of the annual spending formula for endowment return used for operations is to provide sustainable continued future support for ongoing programs at current levels assuming moderate inflation. To the extent that endowment yield is insufficient in any one year to meet the required spending distribution, accumulated net gains are utilized to fund the distribution. For the USNH pool, the distribution rate is established annually by the USNH Board of Trustees. Starting in fiscal year 2019, the USNH pool calculated the distribution as a percentage of the average market value per unit for the previous twelve quarters with a rate of 4.7% and 5.1% as of December 31, 2019 and 2018, respectively. For the UNHF primary pool, the distribution rate was 5.25% as of December 31, for both 2019 and 2018 respectively calculated as a percentage of the average market value per unit for the previous twelve quarters.

The components of endowment return used for operations for 2021 and 2020 are summarized below ($ in thousands):

Components of Endowment Payout 2021 2020

Pooled endowment yield - campuses $ 6,488 $ 3,916 Pooled endowment yield - affiliates (980) 1,834 Trusts, life income and annuities yield, net of gains utilized 564 668 Gains utilized to fund distribution - pooled campuses 17,516 18,162 Gains utilized to fund distribution - pooled affiliates 14,025 10,350 Endowment return used for operations $37,613 $34,930

FiscalYear

Operating Staff

Retirement Plan

Additional Retirement

Contribution Program

Post-retirement

Medical Plan

2022 $(240) $ (176) $ 838 2023 (151) (37) 838 2024 (137) (26) 838 2025 (167) 7 838 2026 – – 838 2027 – – 378

2028 – – 14Total $(695) $ (232) $4,582


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Campuses – current funds Instruction $218,633 $ 10,786 $ (2) $ – $ – $ 229,417 Auxiliary services 44,008 34,426 55 55,893 – 134,382 Research and sponsored programs 83,273 36,915 165 – – 120,353 Academic support 65,690 20,594 – – – 86,284 Student services 38,758 71,777 14 (36) – 110,513 Institutional support 68,563 6,711 77 (17,988) – 57,363 Operations and maintenance 28,696 36,129 15,464 (38,077) – 42,212 Fundraising and communications 9,942 6,250 – 4,307 – 20,499 Public service 13,352 4,298 2 (150) – 17,502 Subtotal – current funds 570,915 227,886 15 ,775 3,949 – 818,525 Campuses - other funds (212) 5,311 – – 68,953 74,052 Affiliated entities 7,319 847 1 (3,949) – 4,218 Total $578,022 $234,044 $15,776 $ – $68,953 $ 896,795

CompensationSupplies

& Services UtilitiesInternal

AllocationsDepreciation &Amortization

2021Total

13. Operating expenses by functionThe following tables summarize USNH’s operating expenses by functional classification for the past two years ($ in thousands):

Campuses – current funds Instruction $201,484 $ 17,701 $ 8 $ – $ – $ 219,193 Auxiliary services 53,565 33,022 213 57,241 – 144,041 Research and sponsored programs 76,197 33,290 59 – – 109,546 Academic support 70,747 16,814 60 – – 87,621 Student services 34,734 17,643 11 (97) – 52,291 Institutional support 46,554 17,524 62 (18,484) – 45,656 Operations and maintenance 24,279 29,912 17,603 (38,946) – 32,848 Fundraising and communications 11,438 7,248 1 4,158 – 22,845 Public service 11,914 3,389 3 1 – 15,307 Subtotal – current funds 530,912 176,543 18,020 3,873 – 729,348 Campuses - other funds 129 12,547 39 – 69,015 81,730 Affiliated entities 6,959 1,471 – (3,873) – 4,557 Total $538,000 $190,561 $18,059 $ – $69,015 $ 815,635

CompensationSupplies

& Services UtilitiesInternal

AllocationsDepreciation &Amortization

2020Total


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14. Net positionIt is USNH’s policy to use restricted funds before accessing unrestricted balances. The table below details USNH’s net position as of June 30, 2021 and 2020 ($ in thousands):

Components of Net Position 2021 2020

Net investment in capital assets $ 722,339 $ 709,337 Restricted financial resources Nonexpendable Historic gift value of endowment - campuses 134,754 131,196 Historic gift value of endowment - affiliated entities 171,812 165,157

Total restricted nonexpendable resources 306,566 296,353

Expendable Held by campuses: Accumulated net gains on endowment 94,413 51,082 Fair value of restricted funds functioning as endowment 18,014 14,628 Gifts, grants and contracts 32,910 40,527 Life income and annuity funds 33 12 Loan funds 2,425 2,853 Held by affiliated entities: Accumulated net gains on endowment 84,055 36,991 Fair value of restricted funds functioning as endowment 56,073 45,913 Other 11,517 8,661

Total restricted expendable resources 299,440 200,667

Unrestricted financial resources Held by campuses: Educational and general reserves (12,259) (14,910) Auxiliary enterprises 45,528 34,651 Internally designated reserves 22,199 45,478 Unrestricted loan funds 1,401 1,438 Unexpended plant funds 101,614 136,073 Fair value of unrestricted funds functioning as endowment 246,033 173,025

Other 862 650 Less: postretirement medical liability(1) (78,490) (88,800) Held by affiliated entities: Fair value of unrestricted funds functioning as endowment 1,616 1,321 Other 1,775 2,061 Total unrestricted financial resources 330,279 290,987 Total Net Position $1,658,624 $1,497,344

(1)As discussed in Note 7, the 2021 and 2020 postretirement medical liability is shown net of the related

deferred inflows and outflows of resources. See Note 10 for additional information in this regard.

15. Commitments and contingenciesThe state of emergency related to COVID-19 declared by the Governor of the State of New Hampshire on March 13, 2020, expired on June 11, 2021. However, COVID-19 continues to impact various parts of USNH operations and financial results. USNH expects to continue to incur additional costs in testing, personal protective equipment, and cleaning. While the significant business disruption seems to be easing with the high rate of vaccination in New Hampshire, there is still considerable uncertainty about the long-term implications of this pandemic on higher education and the ultimate financial impact and duration cannot be estimated at this time.

USNH holds insurance for losses related to real property, as well as professional, envi-ronmental, and general liability claims. Property coverage is limited to $500 million in the aggregate with varying deductible levels. Liability coverage and deductible levels are based on management’s assessments of the risks of related losses. Settlements below the relevant deductible amounts are funded from unrestricted net position.

USNH makes expenditures in connection with restricted government grants and contracts, which are subject to final audit by government agencies. Management is of the opinion that the number of disallowances, if any, sustained through such audits would not materially affect the financial position, results of operations, or cash flows of USNH.

USNH is a defendant in various legal actions arising out of the normal course of its operations. Although the outcome of such actions cannot presently be determined, management is of the opinion that the eventual liability, if any, will not have a material effect on USNH’s financial position, results of operations or cash flows.

16. Component unitsCondensed information from the audited financial statements of the University of New Hampshire Foundation, Inc. (UNHF) is presented below ($ in millions):

2021 2020 Condensed information from the Statements of Net Position as of June 30, Endowment investments $302 $240 Other assets 14 11 Total Assets 316 251 Annuities payable 3 3 Other liabilities and deferred inflows of resources 3 2 Total Liabilities and Deferred Inflows of Resources 6 5 Total Net Position $310 $246

2021 2020 Condensed information from the Statements of Revenues, Expenses and Changes in Net Position for the years ended June 30, Gifts and other support $ 32 $ 30 Investment income 68 4 Total Revenues 100 34 Distributions to UNH 28 26 Administrative and other expenses 8 9 Total Expenses 36 35 Increase/(Decrease) in Net Position $ 64 $ (1)

2021 2020 Condensed information from the Statements of Cash Flows for the years ended June 30, Receipts from gifts and other sources $ 24 $ 27 Payments to UNH and suppliers (37) (36) Net Cash Used in Operating Activities (13) (9) Net Cash Provided By Investing Activities 7 4 Net Cash Provided by Noncapital Financing Activities 6 3 Change in Cash and Equivalents $ – $ (2)

A copy of the complete financial statements for UNHF can be obtained on its website at https://www.unh.edu/give/financial-reports or by contacting the Advancement Finance and Administration Office at (603) 862-1584.

17. Subsequent eventsManagement has evaluated the impact of subsequent events through the date that the financial statements were available for issuance October 25, 2021, and concluded that no material events have occurred which would require recognition or disclosure.


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https://www.unh.edu/give/financial-reports


Postretirement Medical PlanSchedule of Changes in Total OPEB Liability and Related Ratios for the years ended June 30, ($ in thousands):

2021 2020 2019 2018 Service costs $ 1,143 $ 1,247 $ 1,359 $ 1,416 Interest 2,444 3,339 3,024 3,627 Benefit payments (4,795) (5,084) (6,381) (6,923) Differences between expected and actual experience (999) 849 – (1,511) Changes in benefit terms (9,533) (318) – – Changes in assumptions(1) 7,336 7,664 (4,968) (4,857) Net Change in Postretirement Medical Liability (4,404) 7,697 (6,966) (8,248) Total Postretirement Medical Plan Liability - beginning of year 90,441 82,744 89,710 97,958 Total Postretirement Medical Plan Liability - end of year $ 86,037 $ 90,441 $ 82,744 $ 89,710 Current portion $ 5,342 $ 4,412 $ 5,331 $ 5,837 Covered payroll $303,529 $298,040 $290,287 $290,107 Total Liability as a Percentage of Covered Payroll 28.3% 30.3% 28.5% 30.9%

Required Supplemental Information (Unaudited)

Additional Retirement Contribution (ARC) Program Schedule of Changes in Total Pension Liability and Related Ratios for the years ended June 30, ($ in thousands):

2021 2020 2019 2018 2017 Service costs $ 22 $ 37 $ 31 $ 41 $ 103 Interest 52 91 66 88 118 Benefit payments(2) (343) (111) (123) (95) (518) Differences between expected and actual experience – (200) – (89) (328) Changes in assumptions 36 70 (97) 26 (5) Net Change in ARC Liability (233) (113) (123) (29) (630) Total ARC liability at beginning of year 2,058 2,171 2,294 2,323 2,953 Total ARC liability at end of year $ 1,825 $ 2,058 $ 2,171 $ 2,294 $ 2,323 Current portion $ 865 $ 217 $ 200 $ 95 $ 455 Covered payroll $12,732 $22,275 $24,369 $26,646 $29,409 Total Liability as a Percentage of Covered Payroll 14.3% 9.2% 8.9% 8.6% 7.9%

Operating Staff Retirement PlanSchedule of Changes in Net Pension Assets and Related Ratios for the years ended June 30, ($ in thousands):

2021 2020 2019 2018 2017 (3)

Plan Fiduciary Net Position Beginning balance $ 5,863 $ 6,186 $ 6,376 $ 6,700 $ – Employer contributions – – – – 6,700 Plan administrative costs – – (13) (13) – Net investment income 1,143 173 407 274 – Benefit payments (457) (496) (584) (585) – Fiduciary net position $ 6,549 $ 5,863 $ 6,186 $ 6,376 $ 6,700 Total Pension Liability at end of year (4,992) (5,431) (5,875) (5,652) (5,707) Net Pension Asset $ 1,557 $ 432 $ 311 $ 724 $ 993 Plan Net Position as a Percentage of Total Pension Liability 131.2% 108.0% 105.3% 112.8% 117.4%

Plan Pension Liability Beginning balance $ (5,431) $(5,875) $(5,652) $(5,707) $(6,345) Service costs (6) (7) (3) – (20) Interest, net of actuarial gain/loss (41) (65) (290) (292) (298) Benefit payments 457 496 584 585 956 Changes in assumptions 29 20 (514) (238) – Total Pension Liability at end of year $(4,992) $(5,431) $(5,875) $(5,652) $ (5,707) Covered payroll $ (120) $ (815) $ (850) $ (961) $ (1,007) Net Pension Asset as a Percentage of Covered Payroll 1297.5% 53.0% 36.6% 75.3% 98.6%

Notes to Schedules :(1)Changes in assumptions relate to discount rate changes. The rates were 2.1% for FY21, 2.7% for FY20, 4.1% for FY19, and 3.4% FY18 based on a change in the related index. See Note 7 for additional information. (2)Fiscal year 2017 benefit payments included separation costs in larger amounts.(3)Reflects payments and adjustments made before the establishment of the related trust on June 29, 2017.

See accompanying independent auditor’s report.


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30

INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER

FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN

ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS The Governor and Legislative Fiscal Committee, State of New Hampshire, and The Board of Trustees University System of New Hampshire We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial statement audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of the University System of New Hampshire (the System), a component unit of the State of New Hampshire, as of and for the year ended June 30, 2021, and the related notes to the financial statements, which collectively comprise the System’s basic financial statements, and have issued our report thereon dated REPORT DATE. The financial statements of the blended component units, University of New Hampshire Foundation, Inc. and Keene Endowment Association, were not audited in accordance with Government Auditing Standards and accordingly this report does not include reporting on internal controls over financial reporting or instances of reportable noncompliance associated with the blended component units. Internal Control Over Financial Reporting

In planning and performing our audit of the financial statements, we considered the System's internal control over financial reporting (internal control) as a basis for designing audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the System’s internal control. Accordingly, we do not express an opinion on the effectiveness of the System’s internal control. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the System’s financial statements will not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.

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31

Our consideration of internal control was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that have not been identified. Given these limitations, during our audit we did not identify any deficiencies in internal control that we consider to be material weaknesses. However, material weaknesses may exist that have not been identified. Compliance and Other Matters

As part of obtaining reasonable assurance about whether the System’s financial statements are free from material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the financial statement. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. Purpose of this Report

The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the result of that testing, and not to provide an opinion on the effectiveness of the System’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the System’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose. CliftonLarsonAllen LLP

Quincy, Massachusetts REPORT DATE

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32

INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE FOR EACH MAJOR

FEDERAL PROGRAM, REPORT ON INTERNAL CONTROL OVER COMPLIANCE, AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS

REQUIRED BY THE UNIFORM GUIDANCE The Governor and Legislative Fiscal Committee, State of New Hampshire, and The Board of Trustees University System of New Hampshire Report on Compliance for Each Major Federal Program

We have audited the University System of New Hampshire’s (the System) compliance with the types of compliance requirements described in the OMB Compliance Supplement that could have a direct and material effect on each of the System’s major federal programs for the year ended June 30, 2021. The System’s major federal programs are identified in the summary of auditors’ results section of the accompanying schedule of findings and questioned costs. Management’s Responsibility

Management is responsible for compliance with federal statutes, regulations, and the terms and conditions of its federal awards applicable to its federal programs. Auditors’ Responsibility

Our responsibility is to express an opinion on compliance for each of the System’s major federal programs based on our audit of the types of compliance requirements referred to above. We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America; the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States; and the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Those standards and the Uniform Guidance require that we plan and perform the audit to obtain reasonable assurance about whether noncompliance with the types of compliance requirements referred to above that could have a direct and material effect on a major federal program occurred. An audit includes examining, on a test basis, evidence about the System’s compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion on compliance for each major federal program. However, our audit does not provide a legal determination of the System’s compliance.

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Opinion on Each Major Federal Program

In our opinion, the System complied, in all material respects, with the types of compliance requirements referred to above that could have a direct and material effect on each of its major federal programs for the fiscal year ended June 30, 2021. Other Matters

The results of our auditing procedures disclosed instances of noncompliance, which are required to be reported in accordance with the Uniform Guidance and which are described in the accompanying schedule of findings and questioned costs as items 2021-001. Our opinion on each major federal program is not modified with respect to these matters.

They System’s response to the noncompliance findings identified in our audit is described in the accompanying schedule of findings and questioned costs. The System’s response was not subjected to the auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response.

Report on Internal Control Over Compliance

Management of the System is responsible for establishing and maintaining effective internal control over compliance with the types of compliance requirements referred to above. In planning and performing our audit of compliance, we considered the System’s internal control over compliance with the types of requirements that could have a direct and material effect on each major federal program to determine the auditing procedures that are appropriate in the circumstances for the purpose of expressing an opinion on compliance for each major federal program and to test and report on internal control over compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, we do not express an opinion on the effectiveness of the System’s internal control over compliance. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. A material weakness in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance. Our consideration of internal control over compliance was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that have not been identified. We did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses. However, we did identify a certain deficiency in internal control over compliance, described in the accompanying schedule of findings and questioned costs as item 2020-001, that we consider to be significant deficiency.

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34

The System’s response to the internal control over compliance findings identified in our audit is described in the accompanying schedule of findings and questioned costs. The System’s response was not subjected to the auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response. The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the results of that testing based on the requirements of the Uniform Guidance. Accordingly, this report is not suitable for any other purpose. Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance

We have audited the financial statements of the business-type activities of the System as of and for the year ended June 30, 2021, and the related notes to the financial statements, which collectively comprise System’s basic financial statements. We issued our report thereon dated October 25, 2021, which contained unmodified opinions on those financial statements. Our audit was conducted for the purpose of forming opinions on the financial statements that collectively comprise the basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the basic financial statements as a whole. CliftonLarsonAllen LLP

Quincy, Massachusetts REPORT DATE

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UNIVERSITY SYSTEM OF NEW HAMPSHIRE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS

JUNE 30, 2021

See accompanying Notes to Schedule of Expenditures of Federal Awards. 35

Direct Award of Pass through Entity Identifying

Number Pass through Grantor CFDA No.

Amount Passed

Through to Subrecipient

Total Federal Expenditures

Research and Development ClusterDepartment of Agriculture

320000218519247 University of Kentucky 10.contract -$ 35,256$ Direct 10.unknown -$ 135,568$

-$ 170,824$

Direct 10.001 -$ 1,559$

Direct 10.025 -$ 262,312$

2019 SCBG NH Dept of Agriculture Markets & Food 10.170 6,792$ 12,713$

Direct 10.174 -$ 31,564$

68457Z5111201 University of Maryland 10.200 73,697$ 124,069$ 68739Z5111202 University of Maryland 10.200 -$ 3,142$

73,697$ 127,211$

Direct 10.202 -$ 358,218$

Direct 10.203 -$ 1,169,648$

Direct 10.206 -$ 589,468$

Direct 10.207 -$ 6,831$

18010456A00 University of Massachusetts 10.215 -$ 8,308$ GNE1818232231 University of Vermont 10.215 -$ 5,019$ GNE19-198-33243 University of Vermont 10.215 -$ 1,554$ GNE20-235-34268 University of Vermont 10.215 -$ 2,695$ LNE16-346-31064 University of Vermont 10.215 3,019$ 23,229$ LNE1837132231 University of Vermont 10.215 -$ 27,441$ LNE20-403-34268 University of Vermont 10.215 -$ 40,330$ LNE20-413R-34268 University of Vermont 10.215 7,520$ 26,033$ SNE19-08-34268 University of Vermont 10.215 -$ 16,929$ SNE20-008-NH-34268 University of Vermont 10.215 -$ 22,313$

10,539$ 173,851$

Federal Grantor/ Cluster

Title Program Title

Total Grants for Agricultural Research, Special Research Grants

Total Other Department of Agriculture Programs

Total Sustainable Agriculture Research and Education

Acer Access Development Program

Grants for Agricultural Research, Special Research GrantsGrants for Agricultural Research, Special Research Grants

Animal Health and Disease Research

Sustainable Agriculture Research and EducationSustainable Agriculture Research and EducationSustainable Agriculture Research and Education

Cooperative Forestry Research

Payments to Agricultural Experiment Stations Under the Hatch Act

Grants for Agricultural Research Competitive Research Grants

Sustainable Agriculture Research and EducationSustainable Agriculture Research and Education

Sustainable Agriculture Research and EducationSustainable Agriculture Research and EducationSustainable Agriculture Research and EducationSustainable Agriculture Research and EducationSustainable Agriculture Research and Education

Other Department of Agriculture ProgramsOther Department of Agriculture Programs

Agricultural Research Basic and Applied Research

Plant and Animal Disease, Pest Control, and Animal Care

Specialty Crop Block Grant Program - Farm Bill

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UNIVERSITY SYSTEM OF NEW HAMPSHIRE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED)

JUNE 30, 2021




Amount Passed




Title Program Title 6116UNHUSDA8696 Pennsylvania State University 10.303 1$ Direct 10.303 25,216$ 118,517$

25,216$ 118,518$

80289-10774 Cornell University 10.304 -$ 18,511$ SUB00002455 University of Florida 10.305 -$ 24,717$

43,228$

79536-10805 Cornell University 10.307 -$ 47,540$ 33191SUB52700 University of Vermont 10.307 -$ 55,999$ Direct 10.307 -$ 55,834$

-$ 159,373$

F0003750302009 Purdue University 10.309 -$ 66,005$

2019-1507-09 10.310 -$ 8,726$ 60079112 10.310 -$ 1,776$ 00009502 10.310 -$ 23,171$ 2016-68002-24967 10.310 -$ 80,580$ 32375SUB52504 10.310 -$ 21,438$ 42247519119 10.310 -$ 7,214$ Direct 10.310 Agriculture and Food Research Initiative (AFRI) 114,905$ 761,098$

114,905$ 904,003$

Direct 10.319 23,128$ 89,082$

Direct 10.328 -$ 6,616$

8693521120 Cornell University 10.329 -$ 12,494$

Total Integrated Programs

Total Homeland Security Agricultural

Total Organic Agriculture Research and Extension Initiative

Total Agriculture and Food Research Initiative (AFRI)

Agriculture and Food Research Initiative (AFRI)

National Food Safety Training, Education, Extension, Outreach, and Technical Assistance Competitive Grants Program

Integrated ProgramsIntegrated Programs

Agriculture and Food Research Initiative (AFRI)

Organic Agriculture Research and Extension Initiative

Homeland Security AgriculturalHomeland Security Agricultural


Farm Business Management and Benchmarking Competitive Grants Program

Crop Protection and Pest Management Competitive Grants Program

Agriculture and Food Research Initiative (AFRI)Agriculture and Food Research Initiative (AFRI)Agriculture and Food Research Initiative (AFRI)Agriculture and Food Research Initiative (AFRI)


Specialty Crop Research Initiative

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JUNE 30, 2021




Amount Passed




Title Program Title 20-015520 A University of Massachusetts 10.329 -$ 5,682$ AWD00000449SUB0000020 University of Vermont 10.329 -$ 268$ Direct 10.329 -$ 135,731$

-$ 154,175$

Direct 10.351 -$ 2,793$

57335 University of Delaware 10.500 -$ 57,765$ Direct 10.500 2,986$ 14,368$

2,986$ 72,133$

56960 University of Delaware 10.520 -$ 25,358$

AWD00000051SUB0000000 University of Vermont 10.652 -$ 39,548$ AWD00000051SUB0000021 University of Vermont 10.652 -$ 2,481$ AWD00000051SUB0000021 University of Vermont 10.652 -$ 8,317$ Direct 10.652 -$ 40,044$

-$ 90,390$

Direct NH Dept of Natural & Cultural Resources 10.664 -$ 1,392$ NH Dept of Natural & Cultural Resources 10.664 Cooperative Forestry Assistance -$ 734$

13C005 NH Dept of Natural & Cultural Resources 10.664 -$ 90,898$ 13C006 NH Dept of Natural & Cultural Resources 10.664 -$ 53,103$ 13C007 10.664 -$ 29,455$

-$ 175,582$

Direct 10.678 -$ 110,702$

Direct 10.680 -$ 45,761$

FRD-UGP-1010 State of Michigan 10.682 -$ 17,170$

Direct 10.699 -$ 236,256$

040517057630 National Fish & Wildlife Foundation 10.902 -$ 25,904$ 040517057704 National Fish & Wildlife Foundation 10.902 -$ 18,764$

44,668$

Direct 10.912 -$ 61,810$

257,263$ 5,327,822$

Total Crop Protection and Pest Management Competitive Grants Program

Total Cooperative Extension Service

Total Forestry Research

Total Cooperative Forestry Assistance

Total Soil and Water Conservation

Rural Business Development Grant

Crop Protection and Pest Management Competitive Grants Program

Agriculture Risk Management Education Partnerships Competitive Grants Program

Forestry Research

Cooperative Forestry Assistance

Cooperative Forestry Assistance

Cooperative Extension ServiceCooperative Extension Service

Forest Health Protection

National Forest Foundation

Partnership Agreements

Soil and Water Conservation

Cooperative Forestry AssistanceCooperative Forestry Assistance

Forest Stewardship Program

Soil and Water Conservation

Environmental Quality Incentives ProgramTotal Department of Agriculture

Crop Protection and Pest Management Competitive Grants ProgramCrop Protection and Pest Management Competitive Grants Program

Forestry ResearchForestry ResearchForestry Research

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JUNE 30, 2021




Amount Passed




Title Program Title Department of Commerce

Direct 11.contract 7,026$

Direct 11.008 99,725$ 702,978$

Direct 11.011 190,061$ 232,437$

14NL88 NERACOOS 11.012 -$ 11,294$ A008-004 NERACOOS 11.012 -$ 238,813$ A009-004 NERACOOS 11.012 -$ 125,713$ A011-004 NERACOOS 11.012 -$ 59,381$ NA16NOS0120023 NERACOOS 11.012 -$ 12,126$

-$ 447,327$

1210687 Rutgers University 11.017 -$ 78,164$ 367937 University Of Connecticut 11.017 -$ 59,885$ UMS1135 University of Maine 11.017 -$ 14,256$

-$ 152,305$

Direct 11.400

79,732$ 7,183,380$

2020-500 National Estuarine Research Reserve System

11.417-$ 16,817$

NFE NERACOOS 11.417 -$ 852$ G&C APPROVAL #60 NH Department of Environmental Services 11.417 -$ (860)$ 2020-1734-02 North Carolina State University 11.417 -$ 12,423$ 364411 University Of Connecticut 11.417 -$ 18,508$ KFS#5664660 AND PO#426072

University Of Connecticut 11.417-$ 904$

20182019006 University of Puerto Rico 11.417 -$ 14,252$ Direct 11.417 29,837$ 1,684,060$

Total Sea Grant Support29,837$ 1,746,956$

14NJ93 Great Bay Stewards 11.419 -$ (294)$ 14NK04 Great Bay Stewards 11.419 -$ 2$ NMS012 National Estuarine Research Reserve Asn 11.419

-$ 4,034$ 1231978 NH Department of Environmental Services 11.419

-$ 1,674$

Geodetic Surveys and Services (Geodesy and Applications of the National Geodetic Reference System)

NOAA Mission-Related Education Awards

Ocean Exploration

Ocean Acidification Program (OAP)

Ocean Acidification Program (OAP)Total Ocean Acidification Program (OAP)

Integrated Ocean Observing System (IOOS)Integrated Ocean Observing System (IOOS)Integrated Ocean Observing System (IOOS)Integrated Ocean Observing System (IOOS)

Total Integrated Ocean Observing System (IOOS)

Sea Grant Support

Sea Grant SupportSea Grant Support

Coastal Zone Management Administration Awards

Sea Grant Support

Sea Grant Support

Sea Grant SupportSea Grant Support

Coastal Zone Management Administration AwardsCoastal Zone Management Administration Awards


Other Department of Commerce Programs

Integrated Ocean Observing System (IOOS)

Ocean Acidification Program (OAP)

Sea Grant Support

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JUNE 30, 2021




Amount Passed




Title Program Title 2201983 NH Department of Environmental Services 11.419


-$ 6,124$ 031319-060 NH Department of Environmental Services 11.419

-$ 923$ 050620-120 NH Department of Environmental Services 11.419



-$ (5)$ 060519-105 NH Department of Environmental Services 11.419





-$ 2$ 121819-120 NH Department of Environmental Services 11.419 5,999$ 14G309 Rockingham Planning Commission 11.419 -$ -$ 14G307 Strafford Regional Planning 11.419

-$ 3,539$ Total Coastal Zone Management Administration Awards

-$ 329,478$

Direct 11.420 -$ 219,382$

BLOS 18002 Bigelow Laboratories for Ocean Studies 11.427

-$ 9,573$ 14NK08 Manomet, Inc. 11.427

3$ 14G257 Massachusetts, State of 11.427

-$ 1,355$

Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program












Coastal Zone Management Estuarine Research Reserves






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JUNE 30, 2021




Amount Passed




Title Program Title 2021501 National Estuarine Research Reserve

System11.427

-$ 4,229$ Direct 11.427

-$ 138,144$

-$ 153,304$

PO GSA8- 300-04-BIOGEO/ UNH/9/

Consolidated Safety Services Inc 11.432

-$ 39,872$ 81532-Z7554205 University of Maryland 11.432

-$ 162,470$ 0007525-10212019UNH University of Rhode Island 11.432

-$ 1,473,299$ -$ 1,675,641$

05192177 NH Department of Environmental Services 11.437 -$ 8,716$

2105 NE Fishery Management Council 11.441 Regional Fishery Management Councils -$ 6,917$

8006343-02.01 UNH University of Southern Mississippi 11.472 Unallied Science Program -$ 73,122$

A010004 NERACOOS 11.478 -$ 21,727$ A010022 NERACOOS 11.478 -$ 4,329$

-$ 26,056$ Total Department of Commerce

399,355$ 12,965,025$

Department of Defense14BB12 Azimuth Inc 12.contract Other Department of Defense Programs -$ 17,444$ DCS-S-20-014 DCS Corporation 12.contract Other Department of Defense Programs -$ 19,708$ 14BA93 NP Photonics Inc 12.contract Other Department of Defense Programs -$ 4,999$ SC1984001 Physical Sciences, Inc. 12.contract Other Department of Defense Programs -$ 113,293$ 14BA36 Spectral Sciences Inc 12.contract Other Department of Defense Programs -$ 21,236$ Direct 12.contract Other Department of Defense Programs 137,559$ 815,427$ Direct 12.unknown Other Department of Defense Programs -$ 17,031$

Total Other Department of Defense Programs137,559$ 1,009,138$

4303 Mentis Sciences Inc 12.300 Basic and Applied Scientific Research -$ 90,508$ 038600.361374.01 Mississippi State University 12.300 Basic and Applied Scientific Research 58,368$ 78,574$ SUB# 78526300, MPPO S9001452

University of California at San Diego 12.300 Basic and Applied Scientific Research-$ (17,401)$

450560-19119 Virginia Polytechnic Institute and State University

12.300 Basic and Applied Scientific Research-$ 22,008$

Center for Sponsored Coastal Ocean Research Coastal Ocean ProgramCenter for Sponsored Coastal Ocean Research Coastal Ocean Program

Total National Oceanic and Atmospheric Administration (NOAA) Cooperative

Total Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program



National Oceanic and Atmospheric Administration (NOAA) Cooperative Institutes



Pacific Fisheries Data Program

Total Center for Sponsored Coastal Ocean Research Coastal Ocean Program

of 323



JUNE 30, 2021




Amount Passed




Title Program Title Direct 12.300 Basic and Applied Scientific Research 334,765$ 1,830,169$

Total Basic and Applied Scientific Research 393,133$ 2,003,858$

Direct 12.335 -$ 3,880$

KR702816 University of California at San Diego 12.360 Research on Chemical and Biological Defense -$ 28,574$

50407678050 Northeastern University 12.431 Basic Scientific Research -$ 12,156$ Direct 12.431 Basic Scientific Research -$ 206,600$

Total Basic Scientific Research-$ 218,756$

AS 0002 Advanced Regenerative Manufacturing Inst 12.630 Basic, Applied, and Advanced Research in Science and Engineering -$ 52,934$ AS-0001 Advanced Regenerative Manufacturing Inst 12.630 Basic, Applied, and Advanced Research in Science and Engineering -$ 90,498$ EWD0018 Advanced Regenerative Manufacturing Inst 12.630 Basic, Applied, and Advanced Research in Science and Engineering -$ 51,067$ 1303 Rutgers University 12.630 Basic, Applied, and Advanced Research in Science and Engineering -$ 52,259$ KR702847 University of California at San Diego 12.630 Basic, Applied, and Advanced Research in Science and Engineering -$ 118,467$

-$ 365,225$

1556761 University of Colorado 12.800 Air Force Defense Research Sciences Program -$ 273,745$ Direct 12.800 Air Force Defense Research Sciences Program -$ 294,958$

Total Air Force Defense Research Sciences Program -$ 568,703$

6165407 Embry-Riddle Aeronautical University 12.910Research and Technology Development -$ 21,554$

Total Department of Defense 530,692$ 4,219,688$

Department of Housing and Urban Development14G294 County of Cheshire 14.228

(843)$

Direct 14.506 General Research and Technology Activity 27,657$ -$ 26,814$

Total Basic, Applied, and Advanced Research in Science and Engineering

Total Department of Housing and Urban Development

Navy Command, Control, Communications, Computers, Intelligence, Surveillance, and Reconnaissance

Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii

of 323



JUNE 30, 2021




Amount Passed




Title Program Title Department of the Interior

Direct 15.contract Other Department of Interior Programs 404,137$ 857,516$

Direct 15.424 Marine Minerals Activities -$ 2,274$

050620-088 NH Department of Fish & Game 15.634 State Wildlife Grants -$ 32,912$ 05192155 NH Department of Fish & Game 15.634 State Wildlife Grants -$ 17,945$ F18AF00625 Oklahoma Department of Wildlife

Conservation15.634 State Wildlife Grants

-$ 26,271$ SCDNR FY2021-045 SC Department of Natural Resources 15.634 State Wildlife Grants -$ 25,434$

-$ 102,562$

Direct 15.655 Migratory Bird Monitoring, Assessment and Conservation -$ 2,093$

Direct 15.676 Youth Engagement, Education, and Employment -$ 36,822$

Direct 15.805 Assistance to State Water Resources Research Institutes 14,218$ 350,659$

Direct 15.808 U.S. Geological Survey Research and Data Collection 100,770$

02032123 NH Department of Environmental Services 15.814 National Geological and Geophysical Data Preservation -$ 1,553$

AV18NH01 AmericaView Inc 15.815 National Land Remote Sensing Education Outreach and Research -$ 27,018$

Direct 15.945

-$ 3,939$

14NL80 Lamprey River Advisory Committee 15.962 National Wild and Scenic Rivers System -$ 20,282$ 14BA75 Lamprey River Watershed Association 15.962 National Wild and Scenic Rivers System -$ 939$

Total National Wild and Scenic Rivers System -$ 21,221$ Total Department of the Interior

418,355$ 1,506,427$

Total State Wildlife Grants

Cooperative Research and Training Programs – Resources of the National Park System

of 323



JUNE 30, 2021




Amount Passed




Title Program Title

Department of JusticeDirect 16.026 OVW Research and Evaluation Program 61,995$ 62,519$

Direct 16.526 OVW Technical Assistance Initiative -$ 24,648$

656200S001 Westat 16.543 Missing Children's Assistance -$ 103,316$

Direct 16.560

10,096$ 672,445$

050620-164 NH Department of Justice (Attorney General) 16.575 Crime Victim Assistance-$ 275,756$

2019VOC65 NH Department of Justice (Attorney General) 16.575 Crime Victim Assistance

-$ 3,503$ 2020TECH02 NH Department of Justice (Attorney General) 16.575 Crime Victim Assistance

-$ 13,474$ Total Crime Victim Assistance -$ 292,733$

2019-258 EXECUTED 6.5.19 Amoskeag Health 16.582 Crime Victim Assistance/Discretionary Grants-$ 23,713$

2011CD06 NH Department of Justice (Attorney General) 16.727 Enforcing Underage Drinking Laws Program-$ (201)$

646600S001 Westat 16.734 Special Data Collections and Statistical Studies -$ 19,764$

AWARD 6.5.19 Manchester, NH (City of) 16.838 Comprehensive Opioid Abuse Site-Based Program -$ 28,448$ Total Department of Justice

72,091$ 1,227,385$ Department of Labor

Direct 17.502 Occupational Safety and Health Susan Harwood Training Grants 47,925$ Total Department of Labor -$ 47,925$

Department of the StateBL4346829UNH Indiana University 19.415 Professional and Cultural Exchange Programs - Citizen Exchanges 29,689$

Total Department of the State-$ 29,689$

Department of Transportation1003326-002 Minnesota Dept of Transportation 20.contract Other Department of Transportation Programs -$ 29,159$

1034192 Minnesota Dept of Transportation 20.200 Highway Research and Development Program -$ 60,323$ 1035708 Minnesota Dept of Transportation 20.200 Highway Research and Development Program -$ 90,555$ 1036343 Minnesota Dept of Transportation 20.200 Highway Research and Development Program -$ 36,021$

National Institute of Justice Research, Evaluation, and Development Project Grants

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 1036816 Minnesota Dept of Transportation 20.200 Highway Research and Development Program

22,767$ 61,192$ SUB0001622 National Academy of Sciences 20.200 Highway Research and Development Program -$ 37,100$ Y22MTS0018 University of North Carolina 20.200 Highway Research and Development Program -$ 2,907$

Total Highway Research and Development Program 22,767$ 288,098$ Total Department of Transportation

22,767$ 317,257$

Department of the Treasury

13H294 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund-$ 48,500$

13H303 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund-$ 1,318,638$

Total Coronavirus Relief Fund1,367,138$

Total Department of the Treasury -$ 1,367,138$

National Aeronautics and Space Administration900731 Assurance Technology Corp 43.contract Other National Aeronautics and Space Administration Programs -$ 34,530$ 499878Q Southwest Research Institute (SwRI) 43.contract Other National Aeronautics and Space Administration Programs 1,483,712$ 2,394,186$ A99200MO Southwest Research Institute (SwRI) 43.contract Other National Aeronautics and Space Administration Programs -$ 142,178$ N63153ZC Southwest Research Institute (SwRI) 43.contract Other National Aeronautics and Space Administration Programs -$ 2,759$ P62000ZC Southwest Research Institute (SwRI) 43.contract Other National Aeronautics and Space Administration Programs -$ 7,454$ P99038DS Southwest Research Institute (SwRI) 43.contract Other National Aeronautics and Space Administration Programs -$ 91,115$ 00007549 University of California at Berkeley (UCB) 43.contract Other National Aeronautics and Space Administration Programs -$ 74,384$ SA405826326 University of California at Berkeley (UCB) 43.contract Other National Aeronautics and Space Administration Programs -$ 60,912$ S01192-01 University of Iowa 43.contract Other National Aeronautics and Space Administration Programs -$ 556,159$ Direct 43.contract Other National Aeronautics and Space Administration Programs 427,333$ 1,119,915$ MTSUNH06012014 Manufacturing Technical Solutions Inc 43.unknown Other National Aeronautics and Space Administration Programs -$ 3,567$ Direct 43.unknown Other National Aeronautics and Space Administration Programs -$ 37,536$

Total Other National Aeronautics and Space Administration Programs 1,911,045$ 4,524,695$

S414139 California Institute of Technology 43.001 Science -$ 48,033$ S416271 California Institute of Technology 43.001 Science -$ 47,985$ 1110244-438403 Carnegie-mellon Univ 43.001 Science -$ 48,950$ 1110245439458 Carnegie-mellon Univ 43.001 Science -$ 66,894$ R1050 Dartmouth College 43.001 Science -$ 3,829$ R1255 Dartmouth College 43.001 Science -$ 15,705$ R974 Dartmouth College 43.001 Science -$ 145,921$ URK199 Florida Atlantic University 43.001 Science -$ 12,432$ 14NK48 Gordon Research Confr 43.001 Science -$ 253$

of 323



JUNE 30, 2021




Amount Passed




Title Program Title SV111001 Harvard-Smithsonian Center for Astrophysics 43.001 Science -$ 13,518$ 14BA60 Incom Inc 43.001 Science -$ 71,892$ 135260 Johns Hopkins University 43.001 Science 770,056$ 1,264,995$ 149961 Johns Hopkins University 43.001 Science -$ 78,373$ 151382 Johns Hopkins University 43.001 Science 3,162,211$ 5,291,951$ 161888 Johns Hopkins University 43.001 Science -$ 64,689$ 4104042516 Lockheed Martin 43.001 Science -$ 60,211$ UNH-20NAJL08 Predictive Science Inc 43.001 Science -$ 65,028$ SUB0000156 Princeton University 43.001 Science -$ 435,818$ SUB0000191 Princeton University 43.001 Science -$ 296,550$ SUB0000333 Princeton University 43.001 Science -$ 21,358$ SUB0000398 Princeton University 43.001 Science -$ 247,085$ SUB0000460 Princeton University 43.001 Science -$ 20,387$ 0123 Rutgers University 43.001 Science -$ 95,071$ K99053CT Southwest Research Institute (SwRI) 43.001 Science -$ 5,966$ N64200TM Southwest Research Institute (SwRI) 43.001 Science -$ 14,315$ N99061EH Southwest Research Institute (SwRI) 43.001 Science -$ 4,450$ N99071EH Southwest Research Institute (SwRI) 43.001 Science -$ 956,740$ SUBAWD001521 University Corporation for Atmospheric

Research (Colorado)43.001 Science

-$ 86,507$ 2018249 University of Alabama 43.001 Science -$ 17,293$ UAF 180026 University of Alaska 43.001 Science -$ 2,993$ UAF 19-0009 University of Alaska 43.001 Science -$ 83,463$ 2090GWA417 University of California at Los Angeles

(UCLA)43.001 Science

-$ 18,739$ 2090GWA681 University of California at Los Angeles

(UCLA)43.001 Science

-$ 88,342$ 1557050 University of Colorado 43.001 Science -$ 1$ 1557958 University of Colorado 43.001 Science -$ 111,685$ 1559034 University of Colorado 43.001 Science -$ 2,861$ 1559320 University of Colorado 43.001 Science -$ 36,497$ 1559614 University of Colorado 43.001 Science -$ 19,997$ 1001665865 University of Iowa 43.001 Science -$ 275,638$ S01002-01 University of Iowa 43.001 Science -$ 148,551$ S01345-01 University of Iowa 43.001 Science -$ 5$ NASA004801 University of Maryland 43.001 Science -$ 34,891$ 239790A University of Oregon 43.001 Science -$ F-2017-131 University of Toledo 43.001 Science -$ 21,880$ UWSC11897 University of Washington 43.001 Science -$ 15,817$ UWSC9774 University of Washington 43.001 Science -$ 50,443$ WU-20-470 Washington University 43.001 Science -$ 73,566$ 14109UNH West Virginia Univ 43.001 Science -$ 23,805$ Direct 43.001 Science 1,807,913$ 8,289,033$

Total Science 5,740,180$ 18,800,406$

of 323



JUNE 30, 2021




Amount Passed




Title Program Title Direct 43.003 Exploration 267,410$ 556,670$

C21202056UNH Natl Institute of Aerospace Associates 43.008 Office of Stem Engagement (OSTEM) 9,653$ SPOCSUNH OK State Univ Research Foundation Inc 43.008 Office of Stem Engagement (OSTEM) 3,341$ Direct 43.008 Office of Stem Engagement (OSTEM) 124,569$ 128,058$

Total Office of Stem Engagement (OSTEM) 124,569$ 141,052$ Total National Aeronautics and Space Administration 8,043,204$ 24,022,823$

National Foundation on the Arts and the HumanitiesDirect 45.312

COVID-19 National Leadership Grants -$ 3,992$

Total National Foundation on the Arts and the Humanities -$ 3,992$

National Science FoundationUNH Bezoar Laboratories 47.041 Engineering -$ 9,392$ 10001558-028 Purdue University 47.041 Engineering -$ 203,159$ Direct - University of New Hampshire

47.041 COVID-19 Engineering-$ 7,339$

Direct - University of New Hampshire

47.041Engineering 82,861$ 1,224,842$

Total Engineering 82,861$ 1,444,732$


47.049 Mathematical and Physical Sciences-$ 261,636$

1GG015540 Columbia University 47.050 Geosciences

-$ 3,699$ SAPOG15252 Columbia University 47.050 Geosciences

-$ 11,832$ 71423-11280 Cornell University 47.050 Geosciences -$ (347)$ 1376 Dartmouth College 47.050 Geosciences -$ 10,427$ R1150 Dartmouth College 47.050 Geosciences -$ 124,916$ 52681 Marine Biological Laboratory 47.050 Geosciences -$ 62,967$ 1947706 - Plymouth State University

National Science Foundation 47.050 Geosciences-$ 22,743$

2020-01-27 University of Southern Maine 47.050 Geosciences

-$ 5,783$ Direct - University of New Hampshire

47.050 Geosciences204,860$ 3,205,115$

Total Geosciences 204,860$ 3,447,135$

7GG01458602 Columbia University 47.070 Computer and Information Science and Engineering -$ 20,513$ 1659377-UNH MA Green High Performance Computing Ctr 47.070 Computer and Information Science and Engineering

-$ 1,965$

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 2017TS2768 Semiconductor Research Corporation 47.070 Computer and Information Science and Engineering -$ 8,215$ 8GG014586-02 Trustees of Columbia University in the City of

New York47.070 Computer and Information Science and Engineering

-$ 24,231$ Direct - University of New Hampshire

47.070 Computer and Information Science and Engineering-$ 764,260$


47.070 COVID-19 Computer and Information Science and Engineering-$ 37,326$

Total Computer and Information Science and Engineering

-$ 856,510$

3340/200201862/1637685 Cary Institute of Ecosystem Studies 47.074 Biological Sciences -$ 25,931$ 3340-200201866 Cary Institute of Ecosystem Studies 47.074 Biological Sciences 129,905$ 3392200201978 Cary Institute of Ecosystem Studies 47.074 Biological Sciences 16,450$ 131721-5109142 Harvard University 47.074 Biological Sciences 115,145$ 20190137UNH Middlebury College 47.074 Biological Sciences 20,053$ 100334601 Northern Arizona University 47.074 Biological Sciences 5,142$ 100355701 Northern Arizona University 47.074 Biological Sciences 59,708$ 60078897 Ohio State University 47.074 Biological Sciences 2,231$ 116,884$ 2019001 University of Puerto Rico 47.074 Biological Sciences 320,437$ 1419889903 Whitehead Inst for Biomedical Research 47.074 Biological Sciences 11,611$ Direct - University of New Hampshire

47.074 Biological Sciences20,791$ 1,168,222$

Total Biological Sciences 23,022$ 1,989,488$

JDK061-SB-001 University of Idaho 47.075 Social, Behavioral, and Economic Sciences -$ 10,964$ Direct - University of New Hampshire

47.075 Social, Behavioral, and Economic Sciences-$ 145,075$

Total Social, Behavioral, and Economic Sciences -$ 156,039$

17132044C6S01 Hubbard Brook Research Foundation 47.076 Education and Human Resources -$ 2,877$ 17132044C6S02 Hubbard Brook Research Foundation 47.076 Education and Human Resources -$ 52,759$ 2042596 - Plymouth State University

National Science Foundation 47.076 Education and Human Resources-$ 40,952$

451909 University of Arizona 47.076 Education and Human Resources-$ 2,349$

03633987DL University Of New Mexico 47.076 Education and Human Resources -$ 89,306$ 000021-00001A.007.00 University of Northern Colorado 47.076 Education and Human Resources -$ 10,610$ Direct - University of New Hampshire

47.076 Education and Human Resources

4,145$ 1,202,193$ Total Education and Human Resources 4,145$ 1,401,046$

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 425115-A University of San Francisco 47.078 Polar Programs -$ 22,825$ Direct - University of New Hampshire

47.078 Polar Programs-$ 100,404$

Total Polar Programs -$ 123,229$


47.079 Office of International Science and Engineering286,623$ 378,921$

BLOS19001 Bigelow Laboratories for Ocean Studies 47.083 Integrative Activities -$ 181,083$ 00001451 Brown University 47.083 Integrative Activities -$ 40,234$ R1301 Dartmouth College 47.083 Integrative Activities -$ 161,417$ P0540425 University of Alaska 47.083 Integrative Activities -$ 508,683$ UMS1228 University of Maine 47.083 Integrative Activities -$ 420,001$ Direct - University of New Hampshire

47.083 Integrative Activities963,563$ 3,723,853$

Total Integrative Activities 963,563$ 5,035,271$ Total National Science Foundation

1565074 15,094,007$ US Veterans Administration

Direct 64.034

-$ 40,681$ Total US Veterans Administration

-$ 40,681$ Environmental Protection Agency

7SK00043MD General Dynamics Info Technology Inc 66.contract Other Environmental Protection Agency Programs -$ 14,047$ Direct 66.contract Other Environmental Protection Agency Programs -$ 67,659$ Direct 66.unknown Other Environmental Protection Agency Programs -$ 23,498$

Total Other Environmental Protection Agency Programs-$ 105,204$

432178 University Of Connecticut 66.437 Long Island Sound Program -$ 4,725$ 14BA62 Horsley Witten Group Inc 66.454 Water Quality Management Planning -$ 6,955$ 14NL93 NERACOOS 66.456 National Estuary Program -$ 4,162$ UNHYR23CB University of Southern Maine 66.456 National Estuary Program -$ 10,635$ Direct 66.456 National Estuary Program 15,777$ 509,220$

Total National Estuary Program15,777$ 524,017$

100318-048 NH Department of Environmental Services 66.460 Nonpoint Source Implementation Grants -$ 20,380$

Direct 66.509 Science To Achieve Results (STAR) Research Program -$ 53,543$ 06A 202004152869 Maine Department of Environmental

Protection66.605 Performance Partnership Grants

-$ 2,941$ CTB#20181211*0037 Maine Department of Environmental

Protection66.605 Performance Partnership Grants

-$ 9,574$

VA Grants for Adaptive Sports Programs for Disabled Veterans and Disabled Members of the Armed Forces

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 120518-076 NH Department of Environmental Services 66.605 Performance Partnership Grants

-$ 7,730$ 122017-070 NH Department of Environmental Services 66.605 Performance Partnership Grants

-$ 29,682$ Total Performance Partnership Grants -$ 49,927$

030718-042 NH Department of Environmental Services 66.608

-$ 4,957$

082620-037 NH Dept of Agriculture Markets & Food 66.700 Consolidated Pesticide Enforcement Cooperative Agreements -$ 29,531$ SA202031 eXtension Foundation 66.716

-$ 9,774$ SA202128 eXtension Foundation 66.716

-$ 7,998$

-$ 47,303$ Total Environmental Protection Agency

15,777$ 817,011$

Department of EnergySUB202010061 National Renewable Energy Laboratory 81.contract Other Department of Energy Programs -$ 14,637$ SUB202110449 National Renewable Energy Laboratory 81.contract Other Department of Energy Programs -$ 64,165$ UNH1ORPC Pacific Ocean Energy Trust 81.contract Other Department of Energy Programs -$ 8,497$ UNH1RTI Pacific Ocean Energy Trust 81.contract Other Department of Energy Programs -$ 4,673$ NO. S017254 Princeton University 81.contract Other Department of Energy Programs -$ 145,989$ Direct 81.contract Other Department of Energy Programs -$ 121,883$

Total Other Department of Energy Programs -$ 359,844$

60055729 Ohio State University 81.049 Office of Science Financial Assistance Program -$ 3,446$ 61351720-124215 Stanford University 81.049 Office of Science Financial Assistance Program -$ 358,077$ 17009594B00 Univ Of Massachusetts Amherst 81.049 Office of Science Financial Assistance Program -$ 25,877$ Direct 81.049 Office of Science Financial Assistance Program 3,548$ 1,127,037$

Total Office of Science Financial Assistance Program 3,548$ 1,514,437$

Research, Development, Monitoring, Public Education, Outreach, Training, Demonstrations, and Studies

Research, Development, Monitoring, Public Education, Outreach, Training, Demonstrations, and Studies

Total Research, Development, Monitoring, Public Education, Outreach, Training, Demonstrations, and Studies

Environmental Information Exchange Network Grant Program and Related Assistance

of 323



JUNE 30, 2021




Amount Passed




Title Program Title SUB19014 Ocean Renewable Power Company 81.087 Renewable Energy Research and Development 60,226$ 20191243 University of California at Irvine 81.087 Renewable Energy Research and Development 95,889$ Direct 81.087 Renewable Energy Research and Development 207,726$ 360,947$

Total Renewable Energy Research and Development 207,726$ 517,062$

UTA15-001120 University of Texas at Austin 81.089 Fossil Energy Research and Development -$ 58,246$

UMS1188 University of Maine 81.117

-$ 57,149$

138677 NY State Energy Research & Dev Authority 81.119 State Energy Program Special Projects -$ 46,621$

Direct 81.121 Nuclear Energy Research, Development and Demonstration 162,051$ 205,582$

14B995 Trophic LLC 81.135 Advanced Research Projects Agency - Energy 12,997$ 518,674$ Total Department of Energy 386,322$ 3,277,615$

Department of EducationASUB00000347 Arizona State University 84.305 Education Research, Development and Dissemination -$ 75,632$ ASUB00000476 Arizona State University 84.305 Education Research, Development and Dissemination -$ 30,106$ ASUB00000499 Arizona State University 84.305 Education Research, Development and Dissemination -$ 18,070$ 7971PO136756 Boise State University 84.305 Education Research, Development and Dissemination -$ 96$ 7971-PO137538 Boise State University 84.305 Education Research, Development and Dissemination -$ 9,595$ 29338SUB51804 University of Vermont 84.305 Education Research, Development and Dissemination 15,894$ 28,464$

Total Education Research, Development and Dissemination15,894$ 161,963$

Total Department of Education15,894$ 161,963$

Northern Border Regional CommissionDirect 90.601 Northern Border Regional Development -$ 7,594$

Total Northern Border Regional Commission-$ 7,594$

Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/Assistance

of 323



JUNE 30, 2021




Amount Passed




Title Program Title Department of Health and Human Services

2007TH01 APTR (Assoc for Prevention Teaching & Research)

93.contract Other Department of Health and Human Services Programs-$ 5,993$

GC1053501 Dartmouth-Hitchcock Medical Center 93.contract Other Department of Health and Human Services Programs -$ 113,563$ 14NK03 Qualidigm 93.contract Other Department of Health and Human Services Programs -$ 2$ Direct 93.contract COVID-19 Other Department of Health and Human Services Programs -$ 4,286$

Total Other Department of Health and Human Services Programs -$ 123,844$

05011910 NH Department of Health & Human Services 93.048-$ 613,071$

GC10318-01-DGR15236 Dartmouth College 93.087 Enhance Safety of Children Affected by Substance Abuse -$ 25,616$

1062957 NH Dept of Agriculture Markets & Food 93.103 Food and Drug Administration Research -$ 63,370$

073119-017 NH Department of Health & Human Services 93.110 Maternal and Child Health Federal Consolidated Programs-$ 508,831$

Direct 93.110 Maternal and Child Health Federal Consolidated Programs 274,900$ 1,284,082$ Total Maternal and Child Health Federal Consolidated Programs 274,900$ 1,792,913$

14NK15 New Hampshire Coalition Against Domestic Violence

93.136-$ 12,017$


93.136-$ 8,043$

14NL92 New Hampshire Coalition Against Domestic Violence

93.136

-$ 6,148$ 24-1714-0205-003 University Of Nebraska 93.136

-$ 26,623$

-$ 52,831$

000512145SC010 University of Alabama 93.184 COVID-19 Disabilities Prevention -$ 14,975$

14NJ40 Natl Assn of Health Data Organizations 93.226 Research on Healthcare Costs, Quality and Outcomes -$ 10,891$

Direct 93.242 Mental Health Research Grants -$ 111,965$

5H79SM063408-04 County of Cheshire 93.243

-$ 1$ 060618-019 NH Department of Health & Human Services 93.243

55,844$ 243,706$ 1349 Rutgers University 93.243

-$ 10,999$

55,844$ 254,706$

Substance Abuse and Mental Health Services Projects of Regional and National Significance

Substance Abuse and Mental Health Services Projects of Regional and National SignificanceSubstance Abuse and Mental Health Services Projects of Regional and National Significance

Total Substance Abuse and Mental Health Services Projects of Regional and National Significance

COVID-19 Special Programs for the Aging, Title IV, and Title II, Discretionary Projects

Injury Prevention and Control Research and State and Community Based ProgramsInjury Prevention and Control Research and State and Community Based ProgramsInjury Prevention and Control Research and State and Community Based Programs

Injury Prevention and Control Research and State and Community Based Programs

Total Injury Prevention and Control Research and State and Community Based Programs

of 323



JUNE 30, 2021




Amount Passed




Title Program Title Direct 93.262 Occupational Safety and Health Program -$ 148,435$

201001SC Seacoast Science Inc 93.279 Drug Abuse and Addiction Research Programs -$ 30,688$ A202485S001 University of California at Davis 93.279 Drug Abuse and Addiction Research Programs -$ 47,238$

Total Drug Abuse and Addiction Research Programs-$ 77,926$

Direct 93.286

-$ 40,643$

Direct 93.310 Trans-NIH Research Support -$ 16,919$

081419-041 NH Developmental Disabilities Council 93.360

-$ 75,728$

GB10832.PO#2256892 University Of Virginia 93.395 Cancer Treatment Research -$ 14,770$ Direct 93.395 Cancer Treatment Research -$ 71,936$

Total Cancer Treatment Research -$ 86,706$

UCHC7139188778 University Of Connecticut 93.396 Cancer Biology Research -$ 38,606$

Direct 93.398 Cancer Research Manpower -$ 837$

062117-011 NH Department of Health & Human Services 93.426-$ 29,375$

14NK81 National Disability Institute 93.433-$ 11,074$

14NL59 National Disability Institute 93.433

-$ 12,373$ Direct 93.433

74,096$ 1,465,147$

74,096$ 1,488,594$

Direct 93.434 Every Student Succeeds Act/Preschool Development Grants -$ 71,961$

092717-034 New Hampshire Department of Insurance 93.511

-$ 19,971$


93.556 Promoting Safe and Stable Families-$ 24,789$

Discovery and Applied Research for Technological Innovations to Improve Human Health

Biomedical Advanced Research and Development Authority (BARDA), Biodefense Medical Countermeasure Development

Improving the Health of Americans through Prevention and Management of Diabetes and Heart Disease and Stroke

ACL National Institute on Disability, Independent Living, and Rehabilitation ResearchACL National Institute on Disability, Independent Living, and Rehabilitation Research

ACL National Institute on Disability, Independent Living, and Rehabilitation Research

Total ACL National Institute on Disability, Independent Living, and Rehabilitation Research

Affordable Care Act (ACA) Grants to States for Health Insurance Premium Review

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 14NL54 New Hampshire Coalition Against Domestic

Violence93.556 Promoting Safe and Stable Families

-$ 3,000$ Total Promoting Safe and Stable Families -$ 27,789$

Direct 93.632

-$ 578,113$

20-0452 Granite State Childrens Alliance 93.643 Children's Justice Grants to States -$ 39,956$

041719-021 NH Department of Health & Human Services 93.670 Child Abuse and Neglect Discretionary Activities-$ 114,505$

Direct 93.732 Mental and Behavioral Health Education and Training Grants -$ 341,977$

062117-011 NH Department of Health & Human Services 93.758-$ 6,961$

Direct 93.839 Blood Diseases and Resources Research 25,406$ 359,591$

1UT2GM130176-01 Celdara Medical LLC 93.859 Biomedical Research and Research Training -$ 59,942$ 4UT2GM130176-02 Celdara Medical LLC 93.859 Biomedical Research and Research Training -$ 1,739$ DARTMOUTH SUB#1224 Dartmouth College 93.859 Biomedical Research and Research Training -$ (93)$ R1039 Dartmouth College 93.859 Biomedical Research and Research Training -$ (779)$ R1040 Dartmouth College 93.859 Biomedical Research and Research Training -$ (1)$ R1041 YEAR 2 Dartmouth College 93.859 Biomedical Research and Research Training -$ R1044 Dartmouth College 93.859 Biomedical Research and Research Training -$ (66)$ R1045 Dartmouth College 93.859 Biomedical Research and Research Training -$ 2,257$ R1401 Dartmouth College 93.859 Biomedical Research and Research Training -$ 201,933$ R1404 Dartmouth College 93.859 Biomedical Research and Research Training -$ 23,790$ R1410 Dartmouth College 93.859 Biomedical Research and Research Training -$ 16,193$ R1412 Dartmouth College 93.859 Biomedical Research and Research Training -$ 98,576$ R1417 Dartmouth College 93.859 Biomedical Research and Research Training -$ 65,603$ R1418 Dartmouth College 93.859 Biomedical Research and Research Training -$ 285,116$ R1421 Dartmouth College 93.859 Biomedical Research and Research Training -$ 109,431$ R1422 Dartmouth College 93.859 Biomedical Research and Research Training -$ 47,553$ R763 Dartmouth College 93.859 Biomedical Research and Research Training -$ (1)$ R774 Dartmouth College 93.859 Biomedical Research and Research Training -$ (92)$ R919 Dartmouth College 93.859 Biomedical Research and Research Training -$ (1,158)$ SUBAWARD R1416-FY21 Dartmouth College 93.859 Biomedical Research and Research Training -$ 114,938$ 1003287C-UNH University of Wyoming 93.859 Biomedical Research and Research Training -$ (1)$ Direct 93.859 Biomedical Research and Research Training -$ 2,480,002$

Total Biomedical Research and Research Training -$ 3,504,882$

University Centers for Excellence in Developmental Disabilities Education, Research, and Service

Preventive Health and Health Services Block Grant funded solely with Prevention and Public Health Funds (PPHF)

of 323



JUNE 30, 2021




Amount Passed




Title Program Title 1R01HD083072 Center for Innovative Public Health Research 93.865 Child Health and Human Development Extramural Research

-$ 19,442$ OSP2018052 PO #WA00648010

University of Massachusetts 93.865 Child Health and Human Development Extramural Research-$ 123,940$

Total Child Health and Human Development Extramural Research -$ 143,382$

S000780-DHHS Pennsylvania State University 93.866 Aging Research -$ 9,994$ S51110000037006 University of Massachusetts at Lowell 93.866 Aging Research -$ 18,693$ 3004158143 University of Michigan 93.866 Aging Research -$ 25,917$

Total Aging Research -$ 54,604$

Direct 93.867 Vision Research -$ 145,797$

34605SUB53139 University of Vermont 93.912

-$ 235,418$

062020-026 NH Department of Health & Human Services 93.945 Assistance Programs for Chronic Disease Prevention and Control23,991$ 110,721$

062020-026 NH Department of Health & Human Services 93.994 Maternal and Child Health Services Block Grant to the States-$ 162,063$

Total Department of Health and Human Services454,237$ 10,985,642$

Social Security AdministrationSUBK00014588 University of Michigan 96.007 Social Security Research and Demonstration 55,569$

Total Social Security Administration-$ 55,569$

Department of Homeland Security13H312 NH Department of Health & Human Services 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters)

-$ 24,660$

13S066 NH Department of Safety 97.067 Homeland Security Grant Program -$ 26,828$ 13S067 NH Department of Safety 97.067 Homeland Security Grant Program -$ (10,365)$ 13S070 NH Department of Safety 97.067 Homeland Security Grant Program -$ 35,839$ 13S071 NH Department of Safety 97.067 Homeland Security Grant Program -$ 8,716$

Total Homeland Security Grant Program-$ 61,018$

Total Department of Homeland Security-$ 85,678$

12,181,031$ 81,587,745$ Total Research and Development Cluster

Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement

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JUNE 30, 2021




Amount Passed




Title Program Title

Department of AgricultureSNAP Cluster

13H282 NH Department of Health & Human Services 10.561

-$ 1,027,320$ Total SNAP Cluster

-$ 1,027,320$

Forest Service Schools and Roads ClusterDirect 10.666 Schools and Roads - Grants to Counties 6,987$

Total Forest Service Schools and Roads Cluster-$ 6,987$

Total Department of Agriculture-$ 1,034,307$

Department of the InteriorFish and Wildlife Cluster

031120-036 NH Department of Fish & Game 15.605 Sport Fish Restoration

-$ 18,387$

071019-037 NH Department of Fish & Game 15.611 Wildlife Restoration and Basic Hunter Education

-$ 226,472$ 07241338 NH Department of Fish & Game 15.611 Wildlife Restoration and Basic Hunter Education

-$ 98,923$ PG216277701 University of Montana 15.611 Wildlife Restoration and Basic Hunter Education -$ 22,881$

Total Wildlife Restoration and Basic Hunter Education-$ 348,276$

Total Fish and Wildlife Cluster-$ 366,663$

Total Department of the Interior-$ 366,663$

Department of TransportationHighway Planning and Construction Cluster

HR 20-05 (52-17) Natl Cooperative Highway Research Prog 20.205 Highway Planning and Construction

-$ 22,934$ 041719-038 NH Department of Transportation 20.205 Highway Planning and Construction


-$ 60,871$ 05052127 NH Department of Transportation 20.205 Highway Planning and Construction

-$ 3,405$

State Administrative Matching Grants for the Supplemental Nutrition Assistance Program

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JUNE 30, 2021




Amount Passed




Title Program Title

073119-040 NH Department of Transportation 20.205 Highway Planning and Construction




-$ 293,297$ 13T113 NH Department of Transportation 20.205 Highway Planning and Construction

-$ 38,032$ 13T118 NH Department of Transportation 20.205 Highway Planning and Construction


-$ 412,148$ Total Highway Planning and Construction Cluster

-$ 1,020,905$

Federal Transit ClusterDirect 20.507 Federal Transit Formula Grants 766,974$

Total Federal Transit Cluster-$ 766,974$

Highway Safety Cluster061020-097 NH Highway Safety Agency 20.600 State and Community Highway Safety -$ 6,499$

060221113 NH Department of Safety 20.616 National Priority Safety Programs -$ 21,831$ 100219-046 NH Department of Safety 20.616 National Priority Safety Programs

-$ 4,960$ 061020-096 NH Highway Safety Agency 20.616 National Priority Safety Programs -$ 22,861$

Total National Priority Safety Programs-$ 49,652$

Total Highway Safety Cluster-$ 56,151$

Total Department of Transportation-$ 1,844,030$

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JUNE 30, 2021




Amount Passed




Title Program Title Environmental Protection Agency

Drinking Water State Revolving Fund Cluster20210127UNHSUB Sanborn, Head & Associates 66.468 Capitalization Grants for Drinking Water State Revolving Funds

-$ 2,528$ Total Drinking Water State Revolving Fund Cluster

-$ 2,528$ Total Environmental Protection Agency

-$ 2,528$

Department of EducationStudent Financial Assistance Cluster

Direct 84.007 Federal Supplemental Educational Opportunity Grants -$ 2,167,266$

Direct 84.033 Federal Work-Study Program -$ 2,474,367$

Direct 84.038 Federal Perkins Loan Program -$ 13,527,777$

Direct 84.063 Federal Pell Grant Program -$ 23,081,809$

Direct 84.268 Direct Lending Programs - Loans Issued -$ 146,393,943$ Total Student Financial Assistance Cluster

-$ 187,645,162$

TRIO ClusterDirect 84.042 TRIO Student Support Services -$ 1,221,734$

-$ Direct 84.044 TRIO Talent Search -$ 685,454$

-$ Direct 84.047 TRIO Upward Bound -$ 1,161,757$

-$ Direct 84.217 TRIO McNair Post-Baccalaureate Achievement -$ 299,278$

Total TRIO Cluster-$ 3,368,223$

Special Education Cluster (IDEA)2712010312 NH Department of Education 84.027 Special Education Grants to States -$ 34,955$ 73D008 NH Department of Education 84.027 Special Education Grants to States -$ 18,190$ 73D009 NH Department of Education 84.027 Special Education Grants to States -$ 16,139$ IDEA SPECIAL EDUC NH Department of Education 84.027 Special Education Grants to States -$ 2,529$

Total Special Education Grants to States-$ 71,813$

Total Special Education Cluster (IDEA)-$ 71,813$

Total Department of Education-$ 191,085,198$

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JUNE 30, 2021




Amount Passed




Title Program Title Department of Health and Human Services

CCDF ClusterGSC 05/17/17 #15 NH Department of Health & Human Services 93.575 Child Care and Development Block Grant

-$ 254,280$

-$ 254,280$

Medicaid Cluster73N022 Catholic Medical Center 93.778 Medical Assistance Program -$ 61,980$ 14NI39 Network4Health 93.778 Medical Assistance Program

-$ 82,627$ 14NK45 Network4Health 93.778 Medical Assistance Program -$ 55,000$ 062117-011 NH Department of Health & Human Services 93.778 Medical Assistance Program

-$ 963,474$ Total Medical Assistance Program

-$ 1,163,081$ Total Medicaid Cluster

-$ 1,163,081$

-$ 1,417,361$

Social Security AdministrationDisability Insurance/SSI Cluster

51765 Abt Associates Inc 96.001 Social Security Disability Insurance -$ 8,090$ SSA.BPA.UNH.18 Summit Consulting LLC 96.001 Social Security Disability Insurance -$ (2,674)$

Total Disability Insurance/SSI Cluster-$ 5,416$

Total Social Security Administration-$ 5,416$

Department of Agriculture021920-033 NH Dept of Agriculture Markets & Food 10.170 Specialty Crop Block Grant Program - Farm Bill -$ 8,834$

ENE20-166-34268 University of Vermont 10.215 Sustainable Agriculture Research and Education

-$ 29,973$

14NL69 National 4-H Council 10.500 Cooperative Extension Service -$ 11,067$

Direct 10.511 Smith-Lever Funding (Various Programs) -$ 1,342,623$

Direct 10.514 Expanded Food and Nutrition Education Program -$ 322,756$

Direct 10.515 Renewable Resources Extension Act and National Focus Fund Projects -$ 64,363$

Total Department of Health and Human Services

Total CCDF Cluster

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JUNE 30, 2021




Amount Passed




Title Program Title Direct 10.516 Rural Health and Safety Education Competitive Grants Program -$ 65,577$

Direct 10.664 Cooperative Forestry Assistance -$ 72,400$

Direct 10.855 Distance Learning and Telemedicine Loans and Grants-$ 40,942$

Total Department of Agriculture-$ 1,958,535$

Department of CommerceDirect 11.000 Other Department of Commerce Programs -$ 56,575$

Direct 11.020 Cluster Grants -$ 59,761$

12/23/20 University Of Connecticut 11.417 Sea Grant Support -$ 14,777$ Direct 11.417 Sea Grant Support -$ 34,608$

Total Sea Grant Support -$ 49,385$

05052154 NH Department of Environmental Services 11.419 Coastal Zone Management Administration Awards -$ 2,425$

Direct 11.999 Marine Debris Program -$ 22,738$ Total Department of Commerce

-$ 190,884$

Department of DefenseDirect 12.300

Basic and Applied Scientific Research-$ 2,130$

20871112 National Science Teachers Association 12.630Basic, Applied, and Advanced Research in Science and Engineering

-$ 5,405$


-$ 3,306$


-$ 3,306$

Total Basic, Applied, and Advanced Research in Science and Engineering-$ 14,147$

Direct 12.903GenCyber Grants Program

-$ 7,110$

Total Department of Defense -$ 21,257$

Department of Housing and Urban Development20403CDMC2 County of Cheshire 14.228

-$ 85,918$

-$ 85,918$

Total Department of Housing and Urban Development

Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii

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JUNE 30, 2021




Amount Passed




Title Program Title Department of Justice

2020COV36 NH Department of Justice (Attorney General) 16.034-$ 2,659$

PO 1074324 NH Department of Justice (Attorney General) 16.034-$ 120,812$

-$ 123,471$

Direct 16.525

-$ 74,764$

092320-21A NH Department of Health & Human Services 16.540 Juvenile Justice and Delinquency Prevention-$ 156,264$

14NJ08 New Hampshire Coalition Against Domestic Violence

16.575 Crime Victim Assistance-$ 47$

14NJ90 New Hampshire Coalition Against Domestic Violence




14NL28 New Hampshire Coalition Against Domestic Violence

16.575Crime Victim Assistance -$ 130,326$

Total Crime Victim Assistance -$ 130,600$ Total Department of Justice -$ 485,099$

Department of LaborDirect 17.504 Consultation Agreements 478,025$

Total Department of Labor-$ 478,025$

Department of TransportationDirect 20.514 Public Transportation Research, Technical Assistance, and Training

1,452$ Total Department of Transportation

-$ 1,452$

Department of the Treasury14NL75 Cross Roads House 21.019 Coronavirus Relief Fund -$ 66,625$ 13D091 NH Department of Education 21.019 Coronavirus Relief Fund -$ 1,251,055$ 13H300 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund

-$ 12,550$ 2020374 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund

-$ 36,375$

Total CARES ACT: USDOJ Coronavirus Emergency Supplemental Funding (CESF) - Loca

CARES ACT: USDOJ Coronavirus Emergency Supplemental Funding (CESF) - LocaCARES ACT: USDOJ Coronavirus Emergency Supplemental Funding (CESF) - Loca

Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus

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JUNE 30, 2021




Amount Passed




Title Program Title AWARD 03/31/2021 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund

-$ 20,565$ AWARD 1/1/20 NH Department of Health & Human Services 21.019 Coronavirus Relief Fund

-$ 31,875$ 93Z001 NH Office of the Governor 21.019 Coronavirus Relief Fund -$ 28,096,462$ 20197 Volunteer New Hampshire 21.019 Coronavirus Relief Fund -$ 238,492$

Total Coronavirus Relief Fund -$ 29,753,999$ Total Department of the Treasury

-$ 29,753,999$

National Foundation on the Arts and the HumanitiesDirect 45.024 COVID-19 Promotion of the Arts Grants to Organizations and Individuals -$ 50,000$

20-37090 New England Foundation for the Arts 45.025 Promotion of the Arts Partnership Agreements -$ 900$ 20-37091 New England Foundation for the Arts 45.025 Promotion of the Arts Partnership Agreements -$ 5,400$ 20-37191 New England Foundation for the Arts 45.025 Promotion of the Arts Partnership Agreements -$ 7,730$ 13Z164 NH State Council on the Arts 45.025 Promotion of the Arts Partnership Agreements -$ 1,197$ 220848 NH State Council on the Arts 45.025 COVID-19 Promotion of the Arts Partnership Agreements -$ 7,100$ FY2020OPP1#9877 NH State Council on the Arts 45.025 Promotion of the Arts Partnership Agreements -$ (541)$ FY2021OPP2#10246 NH State Council on the Arts 45.025 Promotion of the Arts Partnership Agreements -$ 9,000$

Total Promotion of the Arts Partnership Agreements -$ 30,786$

948-20 New Hampshire Humanities Council, Inc. 45.129 Promotion of the Humanities Federal/State Partnership -$ 250$ 955-20 NH Humanities Council 45.129 Promotion of the Humanities Federal/State Partnership -$ 9,999$

Total Promotion of the Humanities Federal/State Partnership -$ 10,249$

Direct 45.162

-$ 28,349$

-$ 119,384$

Small Business AdministrationDirect 59.037 COVID-19 Small Business Development Centers -$ 607,282$ Direct 59.037 Small Business Development Centers -$ 661,561$

Total Small Business Development Centers-$ 1,268,843$

Direct 59.058 Federal and State Technology Partnership Program-$ 50,826$

Total Small Business Administration-$ 1,319,669$

Total National Foundation on the Arts and the Humanities

Promotion of the Humanities Teaching and Learning Resources and Curriculum Development

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JUNE 30, 2021




Amount Passed




Title Program Title

Department of Veterans AffairsDirect 64.000 Other Department of Veterans Affairs -$ 35,880$ Direct 64.034

-$ 81,129$ Total Department of Veterans Affairs

-$ 117,009$

Environmental Protection AgencyDirect 66.110 Healthy Communities Grant Program -$ 1,281$ SNEP1-05 University of Southern Maine 66.129 Southeast New England Coastal Watershed Restoration -$ 178,490$ Direct 66.514 Science To Achieve Results (STAR) Fellowship Program -$ 3,344$

Total Environmental Protection Agency-$ 183,115$

Department of Education84.184G Laconia School District 84.184

-$ 3,853$ S184M190039 Laconia School District 84.184

-$ 82,582$ S184F180016-20 84.184F NH Department of Education 84.184

-$ 166,501$

-$ 252,936$

M-V SUBGRANT 84.196A Laconia School District 84.196 Education for Homeless Children and Youth -$ 1,327$ H323A170029 NH Department of Education 84.323 Special Education - State Personnel Development -$ 99,695$ H323A170029-18 NH Department of Education 84.323 Special Education - State Personnel Development -$ 13,878$

Total Special Education - State Personnel Development -$ 113,573$

AWARD 7/1/20 New Hampshire Learning Initiative 84.325

-$ 15,172$ Direct 84.325

-$ 407,360$

-$ 422,532$

Direct 84.336 Teacher Quality Partnership Grants -$ 1,023,201$

Total Special Education - Personnel Development to Improve Services and Results for Children with Disabilities

VA Grants for Adaptive Sports Programs for Disabled Veterans and Disabled Members of the Armed Forces

Special Education - Personnel Development to Improve Services and Results for Children with Disabilities

Special Education - Personnel Development to Improve Services and Results for Children with Disabilities

School Safety National Activities (formerly, Safe and Drug-Free Schools and Communities-National Programs)

Total School Safety National Activities (formerly, Safe and Drug-Free Schools and Communities-National Programs)



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JUNE 30, 2021




Amount Passed




Title Program Title

Direct 84.407 Transition Programs for Students with Intellectual Disabilities into Higher Education -$ 120,057$

13D091 NH Department of Education 84.425C COVID-19 Education Stabilization Fund -$ 835,640$ 13D091 NH Department of Education 84.425D COVID-19 Education Stabilization Fund -$ 835,640$ Direct 84.425E COVID-19 Education Stabilization Fund -$ 12,087,559$ Direct 84.425F COVID-19 Education Stabilization Fund -$ 38,807,473$

Total COVID-19 Education Stabilization Fund -$ 52,566,312$

-$ 54,499,938$

Northern Border Regional Commission14UE59 Vermont Technical College 90.601 Northern Border Regional Development

-$ 11,383$

-$ 11,383$

Department of Health & Human ServicesDirect 93.000 COVID-19 Other Department of Health and Human Services Programs -$ 9,811$

5H79SM063408-04

County of Cheshire

93.104

-$ 61,441$ 6H79SM063408-04M003

County of Cheshire

93.104

-$ 28,817$ H79SM0082959 County of Cheshire 93.104

-$ 131,841$ 5H79SM082210-02 Manchester, NH (City of) 93.104

-$ 127,443$ 1H79SM082999-01 NH Department of Education 93.104

-$ 216,421$ SM-16-009 NH Department of Education 93.104

-$ 160,589$

-$ 726,552$

031319-009 NH Department of Health & Human Services 93.136 Injury Prevention and Control Research and State and Community Based Programs

25,039$ 210,727$ Direct 93.184 Disabilities Prevention -$ 445,669$

Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED)


Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED)Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED)

Total Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED)

Total Department of Education



Total Northern Border Regional Commission

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JUNE 30, 2021




Amount Passed




Title Program Title 1H79SM061875-01 Berlin Public Schools 93.243

-$ 2,444$ 1-H79SM082104-01 NAMI NH 93.243

-$ 116,008$ 03252158 NH Department of Education 93.243

-$ 95,283$ IH79SM082054-01 NH Department of Education 93.243

-$ 269,322$ Direct 93.243

-$ 166,409$

-$ 649,466$

14NK66 Lamprey Health Care 93.247 Advanced Nursing Education Workforce Grant Program

-$ 6,465$ Direct 93.247 Advanced Nursing Education Workforce Grant Program 29,617$ 820,181$

Total Advanced Nursing Education Workforce Grant Program

29,617$ 826,646$

19-166 University of Massachusetts 93.279 Drug Abuse and Addiction Research Programs -$ 55,706$ 06292066 NH Department of Education 93.369 ACL Independent Living State Grants -$ 10,771$ 36-21-8814 Assoc of University Centers on Disabilities

(AUCD)93.421

-$ 68,632$ Direct 93.434 -$ 7,715,018$ Direct 93.464 ACL Assistive Technology -$ 410,298$ 14NL13 Org for Refugee & Immigrant Success 93.576 Refugee and Entrant Assistance Discretionary Grants -$ 3,889$ Direct 93.631 Developmental Disabilities Projects of National Significance 16,249$ 370,281$

Total Substance Abuse and Mental Health Services Projects of Regional and National Significance

Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation's Health

Every Student Succeeds Act/Preschool Development Grants






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JUNE 30, 2021




Amount Passed




Title Program Title

Direct 93.632-$ 3,353$

G&C ##78 6/18/14 NH Department of Health & Human Services 93.645 Stephanie Tubbs Jones Child Welfare Services Program -$ (2,027)$ 062018-44C NH Department of Health & Human Services 93.658 Foster Care Title IV-E -$ 140,780$ 1801NHFOST,1801NHADPT,1801NHCW

NH Department of Health & Human Services 93.658 Foster Care Title IV-E

-$ 70,735$ G&C # 35, 5/1/13 NH Department of Health & Human Services 93.658 Foster Care Title IV-E -$ (2,258)$ GSC 02/7/18 #11 NH Department of Health & Human Services 93.658 Foster Care Title IV-E -$ 2,277,894$ GSC 06/15/16 #9A NH Department of Health & Human Services 93.658 Foster Care Title IV-E -$ 6,558$

Total Foster Care Title IV-E-$ 2,493,709$

120220#B NH Department of Health & Human Services 93.665

-$ 31,257$ 062117-011 NH Department of Health & Human Services 93.687 Maternal Opioid Misuse Model -$ 21,342$ Direct 93.732 Mental and Behavioral Health Education and Training Grants -$ 1,239,011$ NB01OT009141 NH Department of Health & Human Services 93.758

-$ 7,781$ Direct 93.788 Opioid STR -$ 168,985$ 062018-22A NH Department of Health & Human Services 93.791 Money Follows the Person Rebalancing Demonstration -$ 371,729$ NU58DP006298 NH Department of Health & Human Services 93.898

-$ 72,441$

6D06RH310570102 The Cheshire Medical Center 93.912

-$ 4,912$ 70,905$ 15,915,959$

Department of Homeland Security062420-174 NH Department of Safety 97.042 COVID-19 Emergency Management Performance Grants -$ 20,161$

13S077 NH Department of Safety 97.067 Homeland Security Grant Program -$ 3,050$ Total Department of Homeland Security

-$ 23,211$ 70,905$ 300,920,340$

Total Expenditures of Federal Awards12,251,936$ 382,508,085$

Total Department of Health and Human Services

COVID-19 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19

Preventive Health and Health Services Block Grant funded solely with Prevention and Public Health Funds (PPHF)

Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations

Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement

University Centers for Excellence in Developmental Disabilities Education, Research, and Service

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NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS YEAR ENDED JUNE 30, 2020

66

NOTE 1 BASIS OF PRESENTATION

The accompanying schedule of expenditures of federal awards (the Schedule) summarizes the expenditures of the University System of New Hampshire (USNH), which includes the University of New Hampshire (UNH), Plymouth State University (PSU), Keene State College (KSC), and Granite State College (GSC) under programs of the federal government for the year ended June 30, 2021. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the consolidated financial position, changes in net assets, or cash flows of the System. For the purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the USNH and the agencies and departments of the federal government pursuant to federal grants, contracts and similar agreements. The Schedule also denotes awards passed through to the USNH to other non-federal organization.

NOTE 2 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Expenditures for federal award programs are recognized as incurred using the accrual method of accounting and the cost accounting principles promulgated under applicable federal circulars. Under those cost principles, certain types of expenditures are not allowable or are limited as to reimbursement and, accordingly, are not reflected as expenditures in the accompanying Schedules. Expenditures also include a portion of costs associated with general operating activities of the respective institutions which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates (Note 3).

NOTE 3 FACILITIES AND ADMINISTRATIVE COSTS

UNH negotiated facilities and administrative cost rates in fiscal year 2019 with its cognizant agency, the U.S. Department of Health and Human Services (DHHS). The on-campus facilities and administrative cost rate in place for UNH is 50.5% of modified total direct costs effective July 1, 2019 until amended. Other rates for UNH facilities and administrative cost recovery range from 26.0% to 57.5% of modified total direct costs. The on-campus facilities and administrative cost rate in place for PSU is 63.9% of direct salaries and wages from July 1, 2021 until amended. The on-campus facilities and administrative cost rate in place for KSC is 53.4% of direct salaries and wages from July 1, 2021 until amended. The on-campus facilities and administrative cost rate in place for GSC is 57.3% of direct salaries and wages from July 1, 2021 until amended.

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NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS YEAR ENDED JUNE 30, 2021

67

NOTE 4 FEDERAL PERKINS LOAN PROGRAM (CFDA 84.038)

The Perkins Loan Program listed below is administered directly by the USNH, and balances and transactions relating to this program are included in the System’s financial statements. The outstanding Perkins Notes Receivable balance as of June 30, 2021 is $10,066,870.

NOTE 5 FEDERAL DIRECT STUDENT LOANS (CFDA 84.268)

Federally guaranteed loans issued to USNH students through the Federal Direct Loan Program (FDL), includes Direct Subsidized and Unsubsidized Stafford Loans, and Direct Parent Loans for Undergraduate Students. These distributions and the related funding sources are not included in the System’s financial statements. Amounts distributed for the FDL program during the year ended June 30, 2021 are summarized as follows:

Stafford Loans:UNH 66,655,763$ PSU 23,189,154 KSC 14,405,849 GSC 5,896,546 Total Stafford Loans 110,147,312

Plus Loans:UNH 22,610,909 PSU 8,165,929 KSC 5,454,758 GSC 15,035 Total Plus Loans 36,246,631

Total Federal Direct Student Loans 146,393,943$

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SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2021

68

Section I – Summary of Auditors’ Results

Financial Statements

1. Type of auditors’ report issued: Unmodified

2. Internal control over financial reporting:

Material weakness(es) identified? yes X no

Significant deficiency(ies) identified? yes X none reported

3. Noncompliance material to financial statements noted? yes X no

Federal Awards

1. Internal control over major federal programs:

Material weakness(es) identified? yes X no

Significant deficiency(ies) identified? X yes none reported

2. Type of auditors’ report issued on compliance for major federal programs: Unmodified

3. Any audit findings disclosed that are required

to be reported in accordance with 2 CFR 200.516(a)? X yes no

Identification of Major Federal Programs CFDA Number(s) Name of Federal Program or Cluster 84.007, 84.033, 84.038, 84.063, 84.268 Student Financial Assistance Cluster 84.425E, 84.425F Higher Education Emergency Relief Fund 21.019 Coronavirus Relief Fund 93.434 Every Student Succeeds Act/Preschool

Development Grants Dollar threshold used to distinguish between Type A and Type B programs: $3,000,000 Auditee qualified as low-risk auditee? X yes no

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SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2021

69

Section II – Financial Statement Findings

Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards.

Section III – Findings and Questioned Costs – Major Federal Programs 2021 – 001 Federal Agency: Department of Education Federal Program Title: CARES HEERF CFDA Number: 84.425E Award Period: July 01, 2020 – June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition During our testing, we noted:

One of the four annual reports tested did not have supporting documentation that agreed to the numbers included in the report and three lacked documentation to prove a review was completed prior to posting to the website

Two of the four quarterly institutional reports tested was not timely submitted and one of the four tested did not have supporting documentation that agreed to the numbers included in the report and two lacked documentation to prove a review was completed prior to posting to the website

Three of the four quarterly student reports tested did not have supporting documentation that agreed to the numbers included in the report, and a lack of documentation to prove a review was completed prior to posting to the website

Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the colleges and universities did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: Due to the urgency to get the information posted to the website within the 30 day timeframe, the University pulled data from their systems but failed to maintain the reports used for numbers posted to the website. The University continued to disburse funds to the students and subsequently the reports changed and the University was not able to recreate the data used for the reporting.

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SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2021

70

Questioned Costs: None Possible Asserted Effect: The documentation doesn’t support the numbers reported on the website and therefore the amounts reported on the website could be inaccurate. Repeat Finding: Yes, 2020-001 Auditor’s Recommendation: We recommend the Universities and College maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website. Views of Responsible Officials: There is no disagreement with the audit finding.

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Item VI. B. Enterprise Risk Management (ERM) Annual Report and Assignment of Risks

MOVED, on recommendation of the Chief Administrative Officer, that the Audit Committee recommends to the Executive Committee the adoption of the following motion: MOVED, on recommendation of the Audit Committee, the Executive Committee hereby formally assigns the top 10 system wide risks identified in the GY 2023 annual ERM report to the appropriate Board committees, as specified in the attachment, for purposes of oversight.

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Presidents’ Council

5 Chenell Drive, Suite 301, Concord, NH 03301 | usnh.edu

ENTERPRISE RISK MANAGMENT

Annual Report to the Board of Trustees’ Audit Committee

GY2023

March 10, 2022 USNH System Wide Risks Process for Identifying, Assessing, and Managing Enterprise Risks: Please refer to the various underlying campus reports and the system office report for a description of the processes that were undertaken to identify and assess enterprise risks and are being undertaken to manage these risks. These processes generated the system wide risk information in the table that is included herein. Each risk factor has been assigned both a likelihood of occurrence and potential impact grade (High, Medium or Low). A number of other risks were identified during the campus and system office ERM processes. Plans to actively manage, or accept, those risks were formulated. These other risks are not included in the various ERM reports because they were not deemed top risks based on the applicable likelihood and impact grades.

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-- 2 --

Summary of the Results of Current Year Process:

Risk Area Accountable Office Description Likelihood Impact

1. Governance Presidents’ Council and Board of Trustees

• System-wide governance structures are evolving in response to rapidly changing needs and opportunities.

• Governance authority is being redistributed between the board of trustees and the administration.

• The Presidents Council (formerly the Administrative Board) is re-establishing its place as the locus of system-wide executive authority.

• System-level executive authority and responsibility are shared among the Interim Chancellor, Presidents’ Council, and Chief Administrative Officer (CAO), creating the potential for gaps, disconnects, and competing priorities.

• System-wide authority and responsibility are both distributed and centralized, placing a premium on collaboration among the incumbents, which in turn depends on their mutual trust and confidence. Collaboration, trust, and confidence among the presidents and with board leadership appear to be at their highest level in system memory but, as is true in any organization, cannot be taken for granted.

• Executive Councils play an important role in the system governance process. Clear delineation of council authority and responsibility will support continued progress.

• System-wide thinking, while necessary to making changes that effectively support the mission, is not yet ingrained in institutional management below the level of the presidents. Awareness of and commitment to a system wide public higher ed mission is an opportunity to strengthen organizational culture and cohesion and support on-going change efforts.

High High

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-- 3 --


• Ongoing administrative restructuring projects are absorbing substantial time, attention, and resources; while the projects are on-track, their success is continually at risk.

• Buy-in by the faculty and staff will be critical to the success of restructuring efforts; individual campus culture, history, and change fatigue will present challenges.

2. Financial Health Presidents’ Council, FINEC

• Declining and changing demographics, increased student financial need, fierce competition, changes in consumer expectations, inflation, etc. are putting extreme pressure on bottom line.

• Dependence on State appropriations to attract and retain resident student population.

• Limited ability to raise prices as a result of significant price sensitivity in the higher education market.

• Volatile financial market which could result in low/negative investment returns and increased borrowing costs.

• Future sizeable strategic investments don’t have the desired effect on mitigating demographic and other uncontrollable higher education trends.

• Fixed cost structure grows after significant cost reductions implemented; temporary expenses become permanent, higher CERP add-backs, employee benefits are not contained (restructuring program not fully implemented), etc.

• Growing mismatch in revenues and costs due to heightened competition, inflation, increased discounting, and limited revenue enhancement options.

• Achieve or exceed Board-mandated ratios, including Operating Margin, and debt covenant requirements.

• Campaign expectations and goals are not met.

High High

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• University does not receive current or additional investments for research.

3. Enrollment & Retention

Presidents’ Council and AEC

• Enrollments and retention rates may fall below target levels. Changes in demographics and general economy/market are significantly impacting enrollment.

• Campus environment or culture or economic factors or background may make it challenging for students to fit in, which can degrade retention

• Inadequate resources to regularly invest and renew infrastructure and facilities can negatively impact enrollment and student retention.

• Available financial aid may not be leveraged in the best possible manner.

• Loss of students during the semester/melt. • Expectation by current and incoming students, post

pandemic, that online courses be offered, and available when needed in individual curriculum

High High

4. New ERP and Major Systems


• Centralized information management and the failure to redesign business processes to fit the software selected

• Failure to address the integration of other USNH software technology/solutions outside of the project scope

• Lack of leadership support • Lack of leadership/ team/ community buy-in • Insufficient/inadequate training and education for end

users • Challenges hiring key project team members in current

labor market • Failure to assign the right people to the project team(s);

knowledge, skillset, emotional intelligence, etc. • Failure to develop and implement an appropriate change

management and communication plan

High High

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-- 5 --


• Existing culture and resistance to change. Current outdated practices may cause resistance to adoption of industry best practices.

• Ability to engage in process re-engineering may be limited (aptitude and time).

5. Talent Management

HREC • Ability to attract, develop, engage, and retain high quality staff needed in current environment may be inadequate.

• Inadequate succession planning. • Hybrid work arrangements/environment; managing

remote employees, paying employees who aren’t working, and complying with state wage and hour laws.

• Low employee morale impacts engagement and productivity. Need to maintain employee morale as significant structural changes are ongoing

• Compensation expense impact due to tight labor market. • Retention of faculty and staff, as salaries have become

very competitive in some key positions. • Lack of talent to meet the strategic demands/needs for

future growth.

High Medium

6. External Forces GREC, Presidents’ Council

• Persistent, perhaps strengthening, voter/policymaker skepticism of the value of a four-year degree, specifically “liberal arts” degrees.

• Shift by political leaders to step in and legislate formerly autonomous matters for the system i.e., Title IX/campus sexual assault, regulation of firearms, free speech issues, and pandemic related oversight issues. Growing adverse spontaneous legislative reactions to individual, individual programs, or campus actions to issues like course offerings, student protests, program cuts or layoffs, and faculty or staff asserting public opinions.

• Closely divided political control at the national level could challenge the appropriations cycle, impacting

Medium Medium

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research and other funding, particularly if there is a government shutdown.

• Impact on operations and funding if there is action on large policy issues such as “free college”, HEA authorization, and Pell grant levels.

7. GSC Integration into UNH


• Need for legislation could affect ability to capture opportunities

• Accreditation approvals must be obtained • Sufficient resources must be allocated for

implementation of restructuring plans • Along with the integration of GSC into UNH-M, the

development of a system-wide online program delivery function will require substantial time, financial resources, and focus.

• IT infrastructure acquisition and development will be necessary to develop the online program delivery function.

• Employees begin to exit because of the high degree of uncertainty.

Medium Medium

8. Information Technology and Security

Finance, IT • IT infrastructure obsolescence can have a negative impact on ongoing operations and cybersecurity.

• Efforts needed to ensure compliance with data security requirements (GLBA, Red Flag Rule, PCI-DSS etc.). Publicized data breach could occur and have an adverse effect to one or more USNH institutions.

• Available technologies and systems are inadequate to ensure data integrity and reporting efficiency.

Medium Medium

9. Compliance Presidents’ Council

• Compliance related duties may not be fulfilled due to resource constraints, inadequate planning, lack of awareness, or knowledge gaps, which may result in regulatory sanctions or significantly impact the brand (reputation).

• Compliance violations may result in regulatory sanctions and lead to a severe brand-impacting situation.

Medium Medium

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10. Academic Programs

Presidents’ Council and AEC

• Weighted 4 year and 6-year undergraduate degree attainment rates are not met.

• Need to identify and refine current major/program offerings to best meet student needs and job market.

• Need to evolve the curriculum to meet local, regional, and national industry needs.

Medium Medium

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USNH ERM GY2023Board Oversight Responsibilities (3)

Assigned Committee Process (1) Risk (2) Champion (4)

ERM Process Compliance Ron Rodgers/Karyl MartinInformation Technology and Security Bill PoirierNew ERP and Major Systems Bill Poirier

Academic Programs Wayne JonesGSC Integration into UNH Wayne JonesEnrollment and Retention Wayne Jones

Executive Governance Cathy Provencher/Jim DeanTalent Management James McGrail

Financial Affairs Financial Health Cathy Provencher

Governance External Forces Ron Rodgers/Karyl Martin

Investments

Nominations

Notes:

Audit

Educational Excellence

(4) - Gather information from appropriate individuals on each campus and in the system office and report the results to the Presidents' Council and the assigned board committee.

(1) - Provides assurance to the full board that risks are being assessed by management with appropriate levels of frequency and diligence.(2) - Provides assurance to the board that the magnitude of the risk hasn't changed significantly (or it has and management has responded accordingly) and related risk mitigation activities continue to be adequate.(3) - These activities can occur at the committee level periodically with management advising the applicable committee if any particular risk warrants review in its next meeting due to changes in circumstances.

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Audit Committee

Motion Sheet

University System of New Hampshire To: Audit Committee Re: Enterprise Risk Management (“ERM”) Annual Report and Assignment of Risks

PROPOSED MOTION

MOVED, on recommendation of the Chief Administrative Officer, that the Audit Committee recommends to the Executive Committee the adoption of the following motion:

MOVED, on recommendation of the Audit Committee, the Executive Committee hereby formally assigns the top 10 system wide risks identified in the GY 2023 annual ERM report to the appropriate Board committees, as specified in the attachment, for purposes of oversight.

SUMMARY OF PROPOSED ACTION

USNH has an Enterprise Risk Management (“ERM”) program that has been designed to identify risks, including emerging risks, and activities that occur to mitigate the risks to an acceptable level. The program consists of risk identification activities that occur on each of the System’s campuses and in the System office annually. Various Board committees are typically updated frequently on risks that fall within their purview. Assignment of risks to USNH Board committees provides a formal process for various committees to review and monitor top 10 risks.

As previously discussed by the Executive Committee and as specified in Board Committee charters, the Executive Committee may choose to formally assign the top 10 risks to the appropriate Board committees for monitoring. A proposed committee assignment list is attached.

Each top risk is assigned a ERM Champion to work with an appropriate team to determine whether there have been activities that have been designed to manage or mitigate the risk. The responsibilities of the ERM Champion are:

1) Gather information from appropriate individuals on each campus and in the System office on periodic basis to: a) determine whether the magnitude of the risk has changed in any significant way (probability of occurrence, potential impact, or both); and b) report on primary activities that are occurring to manage or mitigate the risk, with particular focus on any important new activities; and

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2) Report the status of the risk and related mitigating activities to the Presidents’ Council and assigned board committee.

RATIONALE FOR PROPOSED ACTION

This process will ensure that adequate information is provided to the Board’s committees to help them monitor the top 10 risks.

PREVIOUS REVIEWS AND APPROVALS

The President’s Council discussed the annual report and proposed committee assignment list at its April and May 2022 meetings.

RELEVANT GOVERNANCE DOCUMENTS, POLICIES, AND PRACTICES

As prescribed in the committee charters, the Board’s committees have responsibility to review areas of risk assigned by the Executive Committee for further review or other follow-up based on annual enterprise risk reports from the System’s chief executive officers.

RESOURCE IMPLICATIONS

None

RISK MANAGEMENT CONSIDERATIONS

The assignment of oversight of identified risks to relevant Board committees serves as due diligence component of the USNH enterprise risk management strategy.

SUBSEQUENT ACTION REQUIRED

The proposed action, if adopted, would be a recommendation to the Executive Committee for final action at its next meeting.

ATTACHED MATERIALS – SUMMARY AND SALIENT INFORMATION

A proposed committee assignment list is attached.

SUBMITTED AND APPROVED BY:

Catherine A. Provencher Chief Administrative Officer and Vice Chancellor for Financial Affairs & Treasurer Date Prepared: June 14, 2022 For the Meeting of: June 23, 2022

-- End of Motion Sheet --

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© 2021 University System of New Hampshire. All rights reserved.

USNH Audit CommitteeItem VI. C. Approve FY23 Meeting Schedule and Work Plan

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USNH Audit CommitteeFY23 Meeting Schedule and Work Plan

2

MOVED, on recommendation of the Chief Administrative Officer, that the Audit Committee FY23 Meeting Schedule and Work Plan be approved.

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October 2022 Meeting

Approve FY22 USNH financial statements presented by Mgt.; FAC members invited to attendReview FY22 audit report and comments from CLAReview FY22 financial statements and audit report/comments for UNH FoundationReceive Enterprise Risk Management (ERM) update on assigned risks

January 2023 Meeting

Review Internal Audit’s 2022 annual report and approve 2023 Internal Audit planAccept external auditors’ FY22 single audit reports on USNH federal expenditures Review Internal Audit Charter and determine if updates are neededReview status of outstanding audit issues (first semi-annual update)Receive annual update on Title IX complianceReceive report on anonymous hotline activity and any fraudReceive Enterprise Risk Management (ERM) update on assigned risk


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April 2023 Meeting

Approve appointment of external audit firm for FY23 financial statement auditReceive USNH Environmental Health and Safety Council’s 2022 annual reportReview Enterprise Risk Management (ERM) annual reportReceive Enterprise Risk Management (ERM) update on assigned risks

June 2023 Meeting

Receive GLBA compliance update Review Audit Committee Charter and determine if updates are neededApprove FY24 Meeting Schedule and Work PlanSelf-assess Audit Committee effectiveness Review status of outstanding audit issues (second semi-annual update)Receive Enterprise Risk Management (ERM) update on assigned risks


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© 2021 University System of New Hampshire. All rights reserved.

USNH Council on Environmental Health and Safety2021 Annual Report

Presentation to the Audit Committee of the USNH Board of TrusteesJune 23, 2022

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Andy Glode (Chair) – UNH Katie Caron – PSU Ralph Stuart - KSC Peter Conklin – GSC/UNH-M Lorna Jacobsen – USNH Ashish Jain – USNH (ex-officio)

EHS Council Membership

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UNH PSU KSC GSC USNHPrograms in place 65 35 24 8 9Programs undergoing review, improvement, or under development 1 9 17 - -

Programs not in place - - - - -Not applicable - 22 21 58 57

Total EH&S Compliance Programs

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Hazardous Waste Compliance Inspection

New Hampshire Department of Environmental Services (NHDES) performed a comprehensivehazardous waste compliance inspection at UNH Durham in June, 2021. The final report of theinspection identified no pending action items and no penalties. Inspectors noted at the time of theinspection that UNH has the most complex hazardous waste management program in the state.Achieving this level of compliance is a clear indication of UNH’s cultural commitment to safety andenvironmental stewardship.

Radioactive Material Broad Scope License Renewal

EHS applied with the State of NH for full renewal of its broad scope license for radioactive materialuse. The broad scope license enables UNH to work with a diverse number of radioactive materialswith a high degree of autonomy but requires a comprehensive radiation safety program and activeradiation safety committee to receive approval. UNH fulfilled the rigorous state requirements to begranted the broad scope license.

University of New Hampshire EH&S Update

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Radioactive Materials Source Reduction

EHS worked with UNH researchers to schedule decommissioning of three liquid scintillation counters.Liquid scintillation counters are used to quantify radioactive materials in research samples andcontain a radioactive source. The equipment had become unsupported by the manufacturer, so theirvalue as a research tool was limited. By safely decommissioning the obsolete equipment, UNHreduced risks associated with managing the radioactive material in the equipment.

Research Environmental Growth Chamber Design

EHS convened a group of technical experts to provide support designing a research environmentalgrowth chamber for use with isotopically labeled carbon. Initial design draft exhibited issues relatedto chemical safety and electrical safety. Through a collaborative evaluation process, safety issues weremitigated, greatly improving researcher safety. Chemical and electrical safety were mainconsiderations in design discussions.

University of New Hampshire EH&S Update

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OEHS Co-Lead PSU’s COVID-19 Rapid Response Team (RRT) Interdisciplinary team of professional staff and faculty Managed complex day to day operations regarding COVID-19 Continued to develop University specific policy and protocols as new variants emerged EHS Director, directly responsible for campus wide testing initiative and contact tracing

functions as well as PPE supply, distribution and tracking Acted as the University’s liaison with State of NH Public Health

Reporting of positive cases, discussion of close contacts, documentation of identified clusters

Participated on weekly meetings as part of the USNH (PSU) team with state of NH Public Health Officials

Compliance Status COVID-19 was the priority for PSU in 2021 2022 Focus: use of 3rd party consultants to assist with compliance review and any

subsequent follow up actions EHS vacancy in May of 2020. Proposal to fill in calendar year 2022

Plymouth State University EH&S Update

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Aspect Program goals Status

Regulatory Compliance Status Respond to external review of EHS compliance concerns (this has led to the increase in yellow traffic lights

Reactive program

Emerging Campus Issues Develop resilience plans for new concerns likely to arise (e.g. COVID-19)

Proactive program

Academic Support / Safety Culture Development

provide value to the institutional mission of teaching, research and service (internship program and guest lectures in classes)

Maintaining program

Sector Environmental Scanning identify trends in higher education that are likely to impact KSC (3D printing, nanotech); establish KSC as a national leader in safety education

Proactive program

Keene State College EH&S Program Summary

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Environmental Health and Safety (EHS) planning at Granite State College (GSC) in 2021was focused on our continuing response to the COVID-19 pandemic. GSC Staffremained largely remote, with about a dozen essential staff working at GSC Concord inperson. Weekly PCR testing was arranged for these on site staff through the lab at UNHManchester. Bi-weekly COVID-19 status updates were presented to the College withimportant information on health and safety guidance from public health professionals.Routine safety work like ergonomic evaluations had to be adapted to remote/distancemodalities. Given the merger with UNH, the status of future independent EHS reportsby GSC is a subject of continuing discussion.

GSC has a very small EHS footprint: there are no laboratories, no storage tanks, nodangerous occupational duties, no residential programs, etc.

Granite State College EH&S Update

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Safety concerns at the USNH System Office are primarily associated with life/safetyplanning, office ergonomics, and ongoing mitigation protocols for COVID-19. As aleased facility, building safety issues are directed to building management for resolution.In general, response to these concerns has been prompt and effective.

University System of New Hampshire EH&S Update

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KSC, PSU, GSC, and UNH EHS staff continued to share ideas about mitigation strategiesto address the COVID-19 pandemic. EH&S Council members met with increasedfrequency to facilitate information exchange and planning efforts related to thepandemic.

Council member institutions shared information about increases in indoor moldcomplaints in 2021. Members discussed strategies each institutions takes in addressingindoor air quality complaints, especially mold. Also, strategies in mitigating mold andwater leaks and water intrusion were shared between members. This informationexchange helped ensure consistency and best management practices are utilized acrossUSNH.

USNH EH&S Council Joint Projects

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The Council provides system-wide review and comment at various stages of therulemaking process for new or revised health and safety rules which might impactcampus operations.

The Council reviews proposed bills being considered by the general court and providesinput to each component institution’s administration on the potential impact to campusoperations.

New Hampshire State Legislature andAgencies Regulatory Rulemaking Activities

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Environmental Health and Safety

Perpetuity Hall 11 Leavitt Lane Durham, NH 03824-3522

V: 603.862.4041 F: 603.862.0047 TTY: 7.7.7 (Relay NH)

www.unh.edu/research/ environmental-health-and-safety

June 9, 2022

Ms. Catherine Provencher Chief Administrative Officer and Vice Chancellor for Financial Affairs and Treasurer University System of New Hampshire 5 Chenell Drive, Suite 301 Concord, NH 03301

RE: USNH Environmental Health and Safety Annual Report

Dear Ms. Provencher,

I am pleased to forward you the USNH Environmental Health and Safety Report for 2021. The Board of Trustees (BOT) Operation and Maintenance of Property Policy (VI.F.1.1.3) calls on the Presidents, in collaboration with the Chancellor, to establish procedures to ensure the prudent management of environmental health and safety in compliance with applicable state and federal laws. Those procedures shall include coordination with a Council on Environmental Health and Safety with representation from each component institution. These procedures shall also include, where appropriate, a mechanism for measuring compliance through appropriate means including periodic environmental audits. The Chancellor shall coordinate presentation to the Audit Committee of an annual report describing the state of the University System's environmental health and safety efforts at each institution, including the findings of any environmental audit conducted during the reporting period.

The Council prepared this Annual Report following the elements and objectives stated in the USY Administrative Board Operation and Maintenance of Property Policy (VI.F.3.3.3). The Annual Report contains a summary of compliance status for each component institution, individual campus environmental health and safety reports and a comparison of institution specific compliance progress spreadsheets for 2019, 2020 and 2021.

Please do not hesitate to contact me if you require any additional information.

Sincerely,

Andy Glode, UNH, and Chair

USNH Council on Environmental Health and Safety

Cc: Peter Conklin, GSC

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Ralph Stuart, KSC

Katie Caron, PSU

Lorna Jacobsen, USNH

Ashish Jain, USNH

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1

Executive Summary


Annual Report 2021

This report details USNH Environmental Health and Safety (EHS) program activities for 2021 and presents operational data that represents EHS management efforts conducted by USNH EHS Offices and other University collaborators.

2021 saw a continuation of efforts to manage disruptions caused by the COVID-19 pandemic. Additionally, USNH institutions were challenged with a high number of retirements and resignations; this staffing disruption affected EHS programs directly as experienced staff retired or resigned, and indirectly as talented faculty and staff who helped maintain a culture of safety left USNH. Despite these challenges, USNH EHS programs innovated and persevered, resulting in many notable achievements.

Activities are described by the disciplinary groups responsible for the respective EHS functions at each institution and reflect individual management system plans (goals and objectives) of the campuses. All EHS activities that monitor and otherwise influence operations that present potential environmental impacts are described together. Although described in more detail elsewhere in the report, certain accomplishments credited to this year are listed below in order to highlight the scope and long-term value of the environmental health and safety programs at each campus. Each of the accomplishments is the culmination of persistent efforts of professional USNH EHS staff and all involve extensive collaborations with other USNH departments and support programs.

Granite State College

Environmental Health and Safety (EHS) planning at Granite State College (GSC) in 2021 was focused on our continuing response to the COVID-19 pandemic. GSC Staff remained largely remote, with about a dozen essential staff working at GSC Concord in person. Weekly PCR testing was arranged for these on site staff through the lab at UNH Manchester. Bi-weekly COVID-19 status updates were presented to the College with important information on health and safety guidance from public health professionals. Routine safety work like ergonomic evaluations had to be adapted to remote/distance modalities. Given the merger with UNH, the status of future independent EHS reports by GSC is a subject of continuing discussion.

GSC has a very small EHS footprint: there are no laboratories, no storage tanks, no dangerous occupational duties, no residential programs, etc.

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2

Keene State College

In 2021, Keene State, like higher education in general, faced VUCA conditions - that is, Volatility, Uncertainty, Complexity and Ambiguity in our sector. This is a result of new academic directions, changing market demographics, environmental disruptions to traditional business processes, and shifting operational technologies.

Within this context, the KSC EHS program was able to continue to support the pandemic measures taken by KSC in 2021 with significant emergency assistance from USNH and campus partners and vendors. However, it is increasingly clear that responding to the EHS concerns raised by the Covid pandemic will neither be quick nor conclusive in either the short (1 year) or medium term (3 years).

With this in mind, the KSC EHS program expects to continue to support KSC’s pandemic response, both operationally by providing PPE and ventilation assessment services to address emerging issues from Covid impacts. We expect continued concern about ventilation in our buildings will require ongoing research and interactive communication with campus stakeholders.

Additionally, the Covid response has not only been outside of the traditional regulatory environment, but the pandemic has changed community expectations for environmental conditions. For example, KSC saw mold concerns arise in dorms this fall, partially caused by unusual weather in summer 2021, but also highlighted because of the increased awareness of the dorm population and their parents to environmental conditions in their living spaces.

The KSC EHS program has responded to this VUCA environment by balancing staff resources between regulatory compliance and support of the broader institutional mission of teaching, research, service and sustainability. We have also leveraged partnership with academic departments by increasing the number of student interns employed by the office to assist with both routine operations and research into emerging questions.

Plymouth State University

During 2021, Plymouth State University’s Office of Environmental Health and Safety continued to play an instrumental role in the University’s response to the pandemic and its ongoing planning, monitoring and adaptation of measures to ensure the safety of the campus. Faced with a variety of developing variants emerging with the virus, as a campus, we continued to adopt and develop mitigation strategies, public health policies and operational procedures in our efforts to further navigate the unprecedented health challenges presented to the campus and our community as a result of the pandemic.

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3

As we emerge from the COVID19 crisis, we are asking, what will the post pandemic new normal look like? The global health crisis necessitated creative manners in which organizations had to operate and will undoubtedly continue to present challenges as we move forward in our efforts to recover. Plymouth has developed many tools over the past few years and have learned how to calculate the risks associated with Covid, but chances are we will be dealing with post covid conditions which reach far beyond the immediate health risks we had to address during the pandemic. The pandemic strained organizational resources on many levels. We find ourselves challenged by shortages in staffing, supplies, and finances. Employees have also had to adapt to changing workloads and have had troubles balancing work during the pandemic with their “at home” impacts from COVID19.

As we continue to move forward through 2022 and create the campus’ post pandemic normal, Plymouth State University’s Office of Environmental Health and Safety will focus efforts on transitioning from campus pandemic planning and mitigation, back to its core responsibilities as the department which provides guidance and develops and promulgates policies and practices which protect the campus and our faculty, staff and students from environmental and workplace hazards. The department will certainly continue to act as a resource and provide guidance for campus pandemic related questions, but it is with hope that department focus will return to pre pandemic goals.

Because of the campus’s response to Covid-19 and our global pandemic was the priority for this office during calendar year 2021 and the continued unusual and unprecedented focus this office had in 2021, the use of industry consultants to assist with the identification of regulatory, compliance and programmatic gaps is necessary to clarify and focus on priority areas of concern. In conjunction with these industry consultants, a re-assessment of the goals and objectives, as well as program management, will be completed and areas of concern will be addressed as we continue operations and further safeguard the campus in 2022.

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UNH Office of Environmental Health and Safety (OEHS) has provided essential support and leadership during the pandemic response. Notable accomplishments during 2021 include:


Hampshire Department of Environmental Services (NHDES) performed a comprehensive hazardous waste compliance inspection at UNH Durham in June, 2021. The final report of the inspection identified no pending action items and no penalties. Inspectors noted at the time of the inspection that UNH has the most complex hazardous waste management program in the state. Achieving this level of compliance is a clear indication of UNH’s cultural commitment to safety and environmental stewardship.

Cayuse Hazard Safety Software Design and Roll-Out for Institutional Biosafety Committee

The Research Office purchased a software (Cayuse) for managing research grant awards and many regulatory aspects that go along with grant compliance. One of those aspects is compliance with the National Institutes of Health Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules and oversight by the Institutional Biosafety Committee. EH&S participated in software design, development of supporting materials and implemented a “soft” roll out, with Principal Investigators adding new and renewal protocols into the system as they come up for expiration. Protocol transfer from the UNHCEMS® system to Cayuse IBC will be completed in 2021.

Stillings Hall MMIP Approval

During the fall of 2019, OEHS conducted its annual Monitoring Maintenance and Implementation Plan (MMIP) for Stillings Hall in accordance with the 2010 conditional approval granted by the United States Environmental Protection Agency (EPA) for the removal of windows and associated caulking that contained polychlorinated biphenyls (PCBs). An exceedance was detected during the 2019 surface wipe sampling that required notification to the USEPA and the development of a mitigation plan. The mitigation plan was reviewed by the EPA where they indicated that the current air monitoring action level, which was within the EPA Public Health Levels of PCBs in School Indoor Air, was not protective enough. In 2021 OEHS worked with an environmental engineering firm to request that the EPA revise the proposed action level; EPA approved the request and was granted final approval for the revised MMIP.

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Research Environmental Growth Chamber Support

OEHS convened a group of technical experts to provide support designing a research environmental growth chamber for use with isotopically labeled carbon. Initial design draft design exhibited issues related to chemical safety and electrical safety. Through a collaborative evaluation process, issues were mitigated, greatly improving researcher safety. Chemical and electrical safety were main considerations in design discussions.

Broad Scope License Renewal

OEHS applied with the State of NH for full renewal of its broad scope license for radioactive material use. The broad scope license enables UNH to work with a diverse number of radioactive materials with a high degree of autonomy but requires a comprehensive radiation safety program and active radiation safety committee to receive approval. UNH fulfilled the rigorous state requirements to be granted the broad scope license.


New Hampshire Department of Environmental Services (NHDES) performed a comprehensive hazardous waste compliance inspection at UNH Durham in June, 2021. The final report of the inspection identified no pending action items and no penalties. Inspectors noted at the time of the inspection that UNH has the most complex hazardous waste management program in the state. Achieving this level of compliance is a clear indication of UNH’s cultural commitment to safety and environmental stewardship.

Radioactive Material Source Reduction

OEHS worked with UNH researchers to schedule decommissioning of three liquid scintillation counters. Liquid scintillation counters are used to quantify radioactive materials in research samples and contain a radioactive source. The equipment had become unsupported by the manufacturer, so their value as a research tool was limited. By safely decommissioning the obsolete equipment, UNH reduced risks associated with managing the radioactive material in the equipment.

University System of New Hampshire Central Offices

The University System of New Hampshire’s Central Office is committed to providing and maintaining a safe environment for its employees and visitors. USNH focuses on fire and life safety, hazardous material management, accident prevention, industrial hygiene, and safety and health training. The University System of New Hampshire Central Office complies with all required federal, state and local statutes and with USNH Policy.

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USNH Component Institution Collaboration Efforts

Throughout the global pandemic of 2020 component institutions (KSC, PSU and UNH) collaborated as needed to assist institutions with continuity of operations and ensuring safe and healthful environments. In addition to collaborating on pandemic response and support component institutions strategized on projects such as underground and above ground storage tank management, regulated waste stream compliance initiatives, laboratory safety program management, institutional biological safety and security program management and integrated contingency and spill prevention control and countermeasure plans.

The Council provides system-wide review and comment at various stages of the rulemaking process for new or revised health and safety rules that might affect campus operations.

The Council reviews proposed bills being considered by the general court and provides input to each component institution’s administration on the potential impact to campus operations.

Emerging Issues

Management of issues related to COVID-19 will continue to affect operations at USNH institutions in 2021. The extent to which operations can return to normal will influence long-term impact on EHS compliance and safety programs. As the need for COVID mitigation efforts diminishes, transition to normal staffing and program evaluation can proceed. Re-assessment of the goals and objectives, as well as program management will be priorities for 2021.

UNHCEMS 3.0

OEHS staff will continue to be integral members of the UNHCEMS® development team as UNH Research Computing Center (RCC) continues the UNHCEMS 3.0 project. This multi-year project will continue project team meetings to design, build, and test the latest version of UNHCEMS®. This effort is a complete re-code and re-design of UNHCEMS®. UNH OEHS staff will continue working with members of the RCC and the UNH Innovations team. UNHCEMS provides critical safety and compliance information for UNH institutions; modernizing this system will ensure that the participating institutions can continue to rely on this critical EHS resource.

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Program Elements UNH PSU KSU GSC USNH

3.3.3.1.1 Injury and Illness Prevention

3.3.3.1.2.1 Industrial Hygiene* Asbestos Abatement n n n n n

* Lead Abatement n n n n n

* Hearing Conservation n n n n n

* Indoor Air Quality n n n n n

* Personnel Exposure Monitoring for Toxic Materials n n n n n

* Respiratory Protection n n n n n

* Hazard Communication (GHS) n n n n n

* Heat Stress n n n n n

* Illumination n n n n n

3.3.3.1.2.2 General Safety* Confined Space n n n n n

* Fall Protection n n n n n

* Ergonomic Evaluation n n n n n

* Lock-Out/Tag -Out n n n n n

* Accident Investigation n n n n n

* Powered Industrial Trucks n n n n n

* Cranes & Hoists n n n n n

* Mobile Elevating Work Platforms n n n n n

* Dig Safe Program n n n n n

* Bloodborne Pathogens n n n n n

* Workplace Safety Inspections n n n n n

3.3.3.1.2.3 Radiation Safety & Laser Safety* Radioactive Material License n n n n n

* Radiation Safety Committee n n n n n

* Radioactive Material Inventory n n n n n

* Radiation Safety Manual n n n n n

* User/Awareness Training n n n n n

* Radiation Safety Laboratory Inspections n n n n n

* Dosimetry n n n n n

* Magnet Safety n n n n n

* X-Ray Safety n n n n n

* Radioactive Waste Management n n n n n

* Laser Safety n n n n n

LEGENDProgram in place n

Program undergoing review, improvement, or under development n

Program not in place n

Not Applicable n

USNH Council on Environmental Health and Safety Annual Report - December 2021

Summary of System-wide Compliance Status

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Program Elements UNH PSU KSU GSC USNH3.3.3.1.2.4 Occupational Health and Medicine

* Respirator Medical Questionnaire n n n n n

* Hepatitis B Vaccination n n n n n

* Animal Handlers Occupational Health n n n n n

3.3.3.1.2.5 Integrated Contingency Planning* Aboveground Storage Tank Program n n n n n

* Underground Storage Tank Program n n n n n

* Integrated Contingency/Spill Prevention Control and Countermeasures Plan n n n n n

3.3.3.1.2.6 Biological Safety* Institutional Biosafety Committee n n n n n

* Biosafety Manual n n n n n

* Recombinant DNA Registration n n n n n

* Biosafety Laboratory Surveys n n n n n

* Inventory of Infectious Material n n n n n

* FDA Food Biosecurity Application n n n n n

3.3.3.1.2.7 Diving Safety* Diving Safety Control Board n n n n n

* Diving Safety Officer n n n n n

* Diving Safety Manual n n n n n

3.3.3.2 Hazardous Materials & Environmental Management

3.3.3.2.2.1 Hazardous Waste Management* Hazardous Waste Management Program n n n n n

* EPA Identification Number n n n n n

* Faculty/Staff/Student Training n n n n n

* Contingency Plans for Central Accumulation Area n n n n n

* Satellite Accumulation Area Inspections n n n n n

* Universal Waste Management n n n n n

* Biohazardous Waste Management n n n n n

3.3.3.2.2.2 Hazardous Materials Inventory and Reporting* Chemical Environmental Mgmt System/Inventory System n n n n n

* DEA Controlled Substances Inventory n n n n n

* DHS Chemicals of Interest Inventory n n n n n

* Community Right To Know/SARA Title III n n n n n

* Safety Data Sheets n n n n n

* Chemical Safety/Hygiene Plan n n n n n

* Chemical Laboratory Inspections n n n n n

* Chemical Safety Committee n n n n n

* Title 5 Air Permit n n n n n

* Stormwater Management Plan n n n n n

* Refrigerant Management Plan n n n n n

* Water Quality Permits n n n n n

* Hazardous Materials Shipping n n n n n

Summary of System-wide Compliance Status


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USNH Environmental Health and Safety 2021 Annual Report Component Institution: Granite State College

Environmental Health and Safety (EHS) planning at Granite State College (GSC) in 2021 was focused on our continuing response to the COVID-19 pandemic. GSC Staff remained largely remote, with about a dozen essential staff working at GSC Concord in person. Weekly PCR testing was arranged for these on site staff through the lab at UNH Manchester. Bi-weekly COVID-19 status updates were presented to the College with important information on health and safety guidance from public health professionals. Routine safety work like ergonomic evaluations had to be adapted to remote/distance modalities. Given the merger with UNH, the status of future independent EHS reports by GSC is a subject of continuing discussion. GSC has a very small EHS footprint: there are no laboratories, no storage tanks, no dangerous occupational duties, no residential programs, etc. 1. Mission Statement Granite State College (GSC) is committed to providing and maintaining a healthy and safe environment for students, employees, and visitors by ensuring compliance with legislative requirements as decreed by federal, state and local statutes, USY Policy VI.6 and GSC policy. 2. Authority The Board of Trustees Operation and Maintenance of Property Policy (BOT VI.F.3.3.3) calls on the Chancellor to establish procedures to ensure the prudent management of environmental health and safety in compliance with applicable state and federal laws. These procedures include formation of a Council on Environmental Health and Safety with representation from each component institution and further a delegation of authority

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to the component institutions. In addition, the policy calls for preparation of an annual report describing the status of the University System’s environmental health and safety efforts, as well as providing a mechanism for measuring compliance through periodic audits. The USY Administrative Board Policy on Operation and Maintenance of Property/Policy on Environmental Health and Safety (USYVI.F.3), approved by the President of each component institution, delegates to the President of Granite State College the responsibility for implementing USNH Policy on Environmental Health and Safety for the college. In turn, the President of GSC has delegated this responsibility to the Director of Facilities, Safety, and Sustainability (hereafter GSC Safety Liaison) who will work towards the development and implementation of safety protocols around the College’s six centers/locations:

Conway Center – 53 Technology Lane, Suite 150, Conway, NH (currently leased, not occupied by GSC)

Concord Center – 25 Hall Street, Concord, NH Manchester Center – 1750 Elm Street, Manchester, NH

Dollof Center* - 117 Pleasant Street, Concord, NH

*Child Welfare Education Partnership program with NH DCYF 3. Campus Program Elements and Objectives GSC has adopted a Health and Safety Mission Statement that works to assure safe and healthful environments for all segments of the GSC population through programs of information and education, review and monitoring, and technical consultation as needed. GSC has implemented programs to ensure compliance with applicable state and federal health, safety and environmental regulations, as well as GSC policies on environmental health and safety. Injury and Illness Prevention

a. Industrial Hygiene GSC has access to safety management specialists and outside consultants contracted by USNH to perform air quality monitoring and/or evaluation on an as needed basis. Other types of industrial hygiene are not generally applicable to GSC.

b. General Safety

The primary GSC safety issue is injury control. Ergonomic evaluations are performed as requested. Accident investigation is performed when an

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illness/injury report is filed with human resources, and recommendations are made, if necessary, to prevent recurrence.

c. Radiation Safety

Not applicable

d. Fire Protection The GSC Safety Liaison performs annual site safety inspections of all of the College’s facilities. Part of this inspection addresses fire evacuation routes and planning. Fire safety systems and equipment are inspected annually by licensed external vendors.

d. Occupational Health and Medicine Not applicable

e. Disaster Preparedness

Emergency evacuation procedures address evacuation in case of other disaster. The Emergency Operations Plan addresses in detail disaster preparedness.

f. Biological Safety

Not applicable

g. Diving Safety Not applicable

Hazardous Material & Environmental Management

a. Hazardous Waste Management GSC deals with very little hazardous waste. The only identifiable hazardous waste would be the disposal of fluorescent light bulbs, copier machine toner, and outdated computer monitors. GSC IT staff work with outside vendors to ensure the proper disposal of computer monitors. Each location has protocol in place for proper disposal of fluorescent light bulbs and copier toner.

b. Hazardous Materials Inventory and Reporting

The GSC locations that store janitorial cleaning supplies on site have GHS-SDS information on site, updated by the janitorial companies.

4. Mechanisms to Measure Compliance

GSC measures compliance with safety policy by performing internal audits in the form of safety site evaluations of each center. These evaluations will be scheduled on an annual basis using a checklist of potential safety hazards that was

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created by the GSC Safety Liaison and approved by the UNH Director of Environmental Health and Safety working on behalf of USNH Council of Environmental Health & Safety. This checklist will include the monitoring of facility safety issues, as well as verifying safety procedures are in place for emergency evacuation plans, hazardous materials disposal, and air quality. The GSC Safety Liaison is the safety contact person responsible for safety oversight in all GSC locations. Responsibilities include maintaining and stocking first aid kits, posting emergency exit diagrams, and overseeing the inspection of fire safety systems and equipment.

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Program Elements 2020 2021


3.3.3.1.2.1 Industrial Hygiene* Asbestos Abatement n n

* Lead Abatement n n

* Hearing Conservation n n

* Indoor Air Quality n n

* Personnel Exposure Monitoring for Toxic Materials n n

* Respiratory Protection n n

* Hazard Communication (GHS) n n

* Heat Stress n n

* Illumination n n

3.3.3.1.2.2 General Safety* Confined Space n n

* Fall Protection n n

* Ergonomic Evaluation n n

* Lock-Out/Tag -Out n n

* Accident Investigation n n

* Powered Industrial Trucks n n

* Cranes & Hoists n n

* Mobile Elevating Work Platform n n

* Dig Safe Program n n

* Bloodborne Pathogens n n

* Workplace Safety Inspections n n

3.3.3.1.2.3 Radiation Safety & Laser Safety* Radioactive Material License n n

* Radiation Safety Committee n n

* Radioactive Material Inventory n n

* Radiation Safety Manual n n

* User/Awareness Training n n

* Radiation Safety Laboratory Inspections n n

* Dosimetry n n

* Magnet Safety n n

* X-Ray Safety n n

* Radioactive Waste Management n n

* Laser Safety n n




Not Applicable n


GSC Compliance Status December 2020 and December 2021

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Program Elements 2020 20213.3.3.1.2.4 Occupational Health and Medicine

* Respirator Medical Questionnaire n n

* Hepatitis B Vaccination n n

* Animal Handlers Occupational Health n n

3.3.3.1.2.5 Integrated Contingency Planning* Aboveground Storage Tank Program n n

* Underground Storage Tank Program n n

* Integrated Contingency/Spill Prevention Control and Countermeasures Plan n n

3.3.3.1.2.6 Biological Safety* Institutional Biosafety Committee n n

* Biosafety Manual n n

* Recombinant DNA Registration n n

* Biosafety Laboratory Surveys n n

* Inventory of Infectious Material n n

* FDA Food Biosecurity Application n n

3.3.3.1.2.7 Diving Safety* Diving Safety Control Board n n

* Diving Safety Officer n n

* Diving Safety Manual n n


3.3.3.2.2.1 Hazardous Waste Management* Hazardous Waste Management Program n n

* EPA Identification Number n n

* Faculty/Staff/Student Training n n

* Contingency Plans for Central Accumulation Area n n

* Satellite Accumulation Area Inspections n n

* Universal Waste Management n n

* Biohazardous Waste Management n n

3.3.3.2.2.2 Hazardous Materials Inventory and Reporting* Chemical Environmental Mgmt System/Inventory System n n

* DEA Controlled Substances Inventory n n

* DHS Chemicals of Interest Inventory n n

* Community Right To Know/SARA Title III n n

* Safety Data Sheets n n

* Chemical Safety/Hygiene Plan n n

* Chemical Laboratory Inspections n n

* Chemical Safety Committee n n

* Title 5 Air Permit n n

* Stormwater Management Plan n n

* Refrigerant Management Plan n n

* Water Quality Permits n n

* Hazardous Materials Shipping n n

Annual Report - December 2021GSC Compliance Status December 2020 and December 2021


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USNH Environmental Health and Safety Annual ReportKeene State CollegeCalendar Year 2021

Covid Response

In 2021, Keene State, like higher education in general, faced VUCA conditions - that is, Volatility, Uncertainty, Complexity and Ambiguity in our sector. This is a result of new academic directions, changing market demographics, environmental disruptions to traditional business processes, and shifting operational technologies.

Within this context, the KSC EHS program was able to continue to support the pandemic measures taken by KSC in 2021 with significant emergency assistance from USNH and campus partners and vendors. However, it is increasingly clear that responding to the EHS concerns raised by the Covid pandemic will neither be quick nor conclusive in either the short (1 year) or medium term (3 years).

With this in mind, the KSC EHS program expects to continue to support pandemic response, both operationally by providing PPE and ventilation assessment services to address emerging issues from Covid impacts. We expect continued concern about ventilation in our buildings will require ongoing research and interactive communication with campus stakeholders.

Additionally, the Covid response has not only been outside of the traditional regulatory environment, but the pandemic has changed community expectations for environmental conditions. For example, KSC saw mold concerns arise in dorms this fall, partially caused byunusual weather in summer 2021, but also highlighted because of the increased awareness of the dorm population and their parents to environmental conditions in their living spaces.

The KSC EHS program has responded to this VUCA environment by balancing staff resources between regulatory compliance and support of the broader institutional mission of teaching, research, service and sustainability. We have also leveraged partnership with academic departments by increasing the number of student interns employed by the office to assist with both routine operations and research into emerging questions.

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KSC EHS Program Aspects

The KSC EHS annual report has been organized to reflect this reality by describing four aspects of the program with a brief rating in each of these aspects. The descriptive scale for describing the aspects of the program is:Needs attention: The KSC Reactive: The KSC EHS program can keep up with stakeholder expectations, but is unable to look forward to act on emerging challengesMaintaining: EHS program is able to maintain previous progress in achieving program objectives.Proactive: in addition to meeting stakeholder expectations, EHS staff is able to identify new opportunities to support the academic mission.

The four aspects of the KSC EHS program are:

Regulatory Compliance Status

Current Goal: resolution of compliance concerns within deadline named by inspection agencyKSC Status: reactive programAspects of this program

Environmental health and safety regulatory compliance for:o state air pollution requirements, o state underground storage tanks requirements, o state above ground storage tanks requirements, o state hazardous waste management requirements, o federal and state hazmat emergency planning requirements, o state water supply reporting, o state and city fire code compliance

Occupational safety expectations as identified by external stakeholders (state authorities, research funders and workers compensation carriers)Best practices established outside regulatory requirements (for example ANSI standards as applied to campus facilities such as fume hoods and biosafety cabinets)

Emerging Campus Issues

Current Goal: develop resilience plans for new concerns likely to ariseKSC Status: proactive program

Research and implement Covid risk management techniques in classrooms and public spaces by supplying a variety of types of masks to campus and deploying HEPA air cleaners into classrooms and other public spaces in poorly ventilated buildings.Identify potential mold and other Indoor Air Quality issues campus wide by working with Physical Plant and building managers to address occupant concernsMonitor emerging EHS concerns about Nanotech and 3D printers

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Respond to millennial cultural expectations for environmental health and safety

Academic Support / Safety Culture Development

Goal: demonstrate the direct value of the EHS program to the institutional mission of teaching, research and serviceKSC Status: maintaining program

Teaching support: provide specialized EHS lectures to classes upon faculty request; recruit SOAHS majors to participate in the work of the office; in 2021-2022 five safety majors

compliance and Covid programs.Research support: provide training to research students and consult with faculty and staff about regulatory issues that arise in the research programCommunity Service: work with student groups to provide specialized safety training for activities outside of standard activities (for example, fire extinguisher training for theater and student activities requiring hot work oversight)

Monitor National and Regional EHS trends

KSC Status: proactive programGoal: identify trends in higher education that are likely to impact KSC and establish KSC as a national leader for small college campuses on this topic

Campus sustainability connections: work with KSC Sustainability office to understand the connection between their work and regulatory requirements to leverage synergies between the officesDevelopment of a national academic safety culture: participate in efforts by national organizations, including the American Chemical Society and the Campus Safety Health and Environmental Management Association to understand and promote best practices integrating safety culture concepts into the academic environment.Identify job opportunities and scholarships pertinent to safety students at the regional and national level

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2021 USNH Environmental Health and Safety Annual Report

For


EXECUTIVE SUMMARY During 2021, Plymouth State University’s Office of Environmental Health and Safety continued to play an

instrumental role in the University’s response to the pandemic and its ongoing planning, monitoring and adaptation

of measures to ensure the safety of the campus. Faced with a variety of developing variants emerging with the virus,

as a campus, we continued to adopt and develop mitigation strategies, public health policies and operational

procedures in our efforts to further navigate the unprecedented health challenges presented to the campus and our

community as a result of the pandemic.

As we emerge from the COVID19 crisis, we are asking, what will the post pandemic new normal look like? The global

health crisis necessitated creative manners in which organizations had to operate and will undoubtedly continue to

present challenges as we move forward in our efforts to recover. Plymouth has developed many tools over the past

few years and have learned how to calculate the risks associated with Covid, but chances are we will be dealing with

post covid conditions which reach far beyond the immediate health risks we had to address during the pandemic. The

pandemic strained organizational resources on many levels. We find ourselves challenged by shortages in staffing,

supplies, and finances. Employees have also had to adapt to changing workloads and have had troubles balancing

work during the pandemic with their “at home” impacts from COVID19.

As we continue to move forward through 2022 and create the campus’ post pandemic normal, Plymouth State

University’s Office of Environmental Health and Safety will focus efforts on transitioning from campus pandemic

planning and mitigation, back to its core responsibilities as the department which provides guidance and develops and

promulgates policies and practices which protect the campus and our faculty, staff and students from environmental

and workplace hazards. The department will certainly continue to act as a resource and provide guidance for campus

pandemic related questions, but it is with hope that department focus will return to pre pandemic goals.

Because of the campus’s response to Covid-19 and our global pandemic was the priority for this office during calendar

year 2021 and the continued unusual and unprecedented focus this office had in 2021, the use of industry consultants

to assist with the identification of regulatory, compliance and programmatic gaps is necessary to clarify and focus on

priority areas of concern. In conjunction with these industry consultants, a re-assessment of the goals and objectives,

as well as program management, will be completed and areas of concern will be addressed as we continue operations

and further safeguard the campus in 2022.

The Office of Environmental Health and Safety remains committed to providing, and continually improving, a healthy

and safe living, learning, and working environment for students, faculty, and staff. It is the responsibility of the

Environmental Health and Safety team to help every individual on campus understand their role and responsibility for

safety. The following report summarizes with detail the elements and activity of this office in 2021.

It is with sincere gratitude that I take this opportunity to thank those members of the Plymouth State University

community for the dedication and continued collaboration as we navigated another challenging year. We have much

work to do as a campus, a community and a nation as we forge forward but we will emerge successful. I look forward

to our continued teamwork as a campus and a community.

Katie Caron, Director

Office of Environmental Health & Safety


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COVID-19 ACCOMPLISHMENTS by the PSU Rapid Response Team

▪ Behavior Expectations, Enforcement, and Education

▪ As local public health and CDC guidance changed, behavior expectations, along

with enforcement and education, were modified to meet the most recent public

health guidelines and university requirements.

▪ Established enforcement protocols for noncompliance with COVID-19 safety

policies.

▪ Testing and Screening

▪ Continued to determine testing methods and frequencies based on local and

federal public health guidelines as well as community and state transmission

levels. Both COVID-19 PCR and antigen test methods were utilized during

calendar year 2021.

▪ Developed a campus-wide mandatory testing schedule for both the Fall of 2021

and Spring of 2022 semesters for students, faculty, and staff.

▪ This testing scheduling involved a continuous evaluation based on number

of COVID-19 cases within the community, county, and state.

▪ Created and implemented a new rapid testing program for students, faculty

and staff. This included creating a distribution system, tracking system for

inventory and federal funding reimbursement, as well as identifying a

proper storage location.

▪ Retesting intervals and needs. This included outreach and retesting for

individuals that received an inconclusive test result, or test not processed.

▪ Documenting and tracking compliance status with mandatory testing requirements

for students, faculty, and staff.

▪ Worked with UNH to develop and implement the Panther Pass. The

Panther pass is an app that can be viewed by select groups of PSU

employees. This app allows PSU staff to see if a student is participating in

the required COVID19 testing. This app does NOT communicate a test

result, just participation in the campus’s mandatory COVID19 testing

program. For example, faculty who are instructing classes, the Dining

Hall, Event Staff, as well as the on-campus gym could utilize this tool in

an effort to ensure students participating in classes or activities were also

participating in mandatory testing.

▪ Management of a safe, on campus testing environment.

▪ Continued working with a contracted with a vendor with expertise to perform

observed COVID19 testing.

▪ Transitioned laboratory analysis of samples to the University System of New

Hampshire (UNH) laboratory. This included updating and coordinating the

appropriate technology for receiving and managing test results and well proactive

communication to the campus.

▪ Partnered with the State of NH to coordinate multiple on campus vaccine clinics

for faculty, staff, and students.

▪ Contact Tracing & State of NH Public Health Functions

▪ PSU continued to implement contact tracing protocols and procedures developed

during 2020.

▪ Contact tracing functions were continually reviewed as state and federal

public health guidelines were modified.

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▪ Provided training to PSU employees who completed contact tracing functions as

part of the Rapid Response Team. On-boarded new members to the contact

tracing team.

▪ Continued to utilize the tracking and compliance tool to manage data for contact

tracing efforts which included, but was not limited to, tracking all students,

faculty and staff who were in isolation, quarantine, travel quarantine, as well as a

watchlist for those with exposures. This also included additional items for data

tracking needs. This tool was continuously updated, improved, and modified to

provide data requested by campus leadership.

▪ Reported data regularly via a dashboard available to PSU as well as the

surrounding community via website and town hall meetings.

▪ Continued direct communication with site contacts for the State of NH Public

Health outreach and guidance, including the reporting of positive cases, close

contacts, clusters, and general communication and guidance regarding COVID-

19.

▪ Participated in USNH-specific meetings with the State of NH’s top Public Health

experts as scheduled.

▪ Trained and onboarded a new COVID-19 testing coordinator.

▪ Created and implemented a new process for faculty, staff, and students to end

isolation early on day six (6) through day ten (10) with a negative antigen (rapid

test).

▪ Trained and onboarded a new employee to manage the new isolation exit

process.

▪ Isolation & Quarantine

▪ In the fall of 2020 to the spring of 2021, PSU rented three hotels for offsite

isolation and quarantine. An entire workflow was created and implemented to

manage and operate these facilities. In preparation for the fall of 2021, PSU

utilized an on-campus residence hall for isolation and quarantine purposes. A

new workflow and process was created and implemented to manage and operate

the on-campus isolation and quarantine process and facility. These workflows

included items from 24/7 staffing, emergency and first aid management, health

monitoring, cleaning, bedding/linen, meals, to facility (building) response.

▪ Classroom Spacing, Sanitization and Disinfection

▪ Continued to evaluate COVID-19 classroom occupancies and spacing to address

social distancing recommendations by NH Public Health experts. Adjusted this as

needed based on guidance from both the state and federal levels.

▪ Sanitization and disinfection materials were provided to every classroom space to

allow access to COVID-19 disinfection materials.

▪ Personal Protective Equipment (PPE)

▪ Continued to work with UNH personnel regarding PPE distribution to PSU’s

Campus.

▪ Continued to receive and track PPE requests via the PPE request form developed

in 2021 managed by an onsite PSU team. This form tracks requests and

distribution across campus. This tracking tool is used not only for requests and

distribution but to also track for potential federal funding for reimbursement. This

includes items such as face masks, gloves as well as hand sanitizer and

sanitization wipes.

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CAMPUS PROGRAM ELEMENTS

Plymouth State University’s Office of Environmental Health and Safety is responsible for the

development and management of the University’s environmental health and safety programs.

Areas of responsibility include

• Industrial Hygiene

• Workplace Safety & Training

• Radiation Safety

• Fire and Life Safety

• Occupational Health

• Risk Management

• Integrated Contingency Planning

• Biological and Chemical Safety

• Material Management/Hazardous

• Accident Prevention

• Environmental Compliance

• Emergency Response

PSU is committed in its compliance with all required Federal, State and Local statutes and

ordinances, as well as with USNH Policy. Plymouth State University utilizes a “Traffic Light

Summary” system to assist in identifying the compliance status of a number of Plymouth State

University’s key EHS program elements. The “Traffic Light Summary” may be found as an

attachment at the end of this report.

CAMPUS SAFETY COMMITTEE(s)

The Campus Safety Committee serves as a central coordinating body for several areas of the

University concerned with aspects of safety and security. The committee consists of representation

from a variety of disciplines and departments across campus including Athletics, Art, Science,

University Police, Facility Services, as well as representation from both Professional/Technical

(PAT) and Operating (OS) staff. Previously, membership also included a representative from the

Human Resources Department. During 2021, the Human Resource’s Office was part of a system

wide initiative which included the restructuring and re-allocation of duties across the USNH

system as well as at PSU. Based on the new organizational structure, Human Resources

departmental membership will be revisited during 2022 with a goal to determine availability and

need. During calendar year 2021 the campus safety committee issued a winter safety newsletter.

The committee published this winter safety newsletter which discusses a variety of topics,

including the importance of following curtailment guidelines, subscribing to the University’s text

alert system and winter safety tips. The effort and emphasis on winter safety communication

continues to serve as a proactive campaign to increase knowledge and awareness relative to winter

hazards. The desired outcome of this campaign is to reduce the number of slip and fall cases

reported during the winter months, all of which can directly affect workers compensation claims

and cost.

The Boyd Safety Committee, created in 2015, takes its name from the Boyd Science Center. This

Committee specifically focuses on safe practices in the science disciplines at PSU and seeks to

meet semi-annually. Membership includes representatives from Atmospheric Science, Chemistry

and Biology, as well as the Center for The Environment. Often, this committee meets on an “as

needed” basis. This committee did not meet during calendar year 2021 due to ongoing COVID-

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19 challenges and priorities. The EHS Office’s goal is to begin to meet again in the fall of 2022 if

the committee members agree.

INJURY AND ILLNESS PREVENTION

Plymouth State’s Facilities Department has undergone a significant reduction in available labor

over the past year due to staff turnover, retirements, and the overall impact of reduced resources

surrounding the COVID19 pandemic. With this staffing reduction came the loss of several

seasoned trades employees familiar with many of the EHS programs discussed below.

Comprehensive training during 2022 will be prioritized to ensure that all new employees are

trained appropriately and gaps due to employee changeover are managed while maximizing

program education.

Specific comments for each EHS program are listed below.

INDUSTRIAL HYGIENE

During calendar year 2021, industrial hygiene needs at Plymouth State University were minimal.

There was one industrial hygiene service completed related to indoor air quality/mold.

Additionally, there were a minimal number of projects completed, largely due to the pandemic.

There were no asbestos abatements during calendar year 2021. This was also largely due to the

ongoing COVID19 pandemic. All abatements follow industry specific safety and environmental

regulations. All monitoring reports are on file and available for review in the EHS office.

WORKPLACE SAFETY & TRAINING

In 2021, total workers’ compensation claims reported for PSU totaled twelve (12) cases and

yielded expenses totaling $71,985 for the calendar year. Case totals increased slightly from 2020

to 2021 by two (2) cases. Both calendar years 2020 and 2021 saw a fairly significant decrease in

the total number of cases (by about half). This is likely due to the impacts of Covid-19 and the

transition to remote work plans as part of the University’s pandemic response planning. During

2020 and through the summer of 2021, non-essential employees were encouraged, particularly

during the peak of the pandemic, to work remotely while students were not living, learning, or

working on campus. In calendar year 2020, strategically, PSU ended the fall semester at the end

of November in anticipation of COVID-19 peak transmission (2020 peak) in the state of NH. As

indicated above, during this time many non-essential employees were working remotely until mid

to late January of 2021. This coincides with peak slip and fall season related to winter weather,

which likely accounts for a portion of the decrease in workers compensation claims in calendar

year 2020.

When reporting on case totals it is important to note the distinction between the types of claims

included in this total. There are four criteria/distinctions considered when reporting total number

of cases. The first distinction identifies “report only” claims and includes claims which are reported

only and do not result in medical treatment or time away from work. The second distinction

identifies “medical treatment only” which include claims resulting in medical treatment only but

not lost time or days away from work. The third distinction identifies claims resulting in lost time

away from work but did not receive medical treatment. The final distinction identifies claims

resulting in both medical treatment and lost time or days away from work.

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The total number of claims that resulted in lost time or days away from work stayed the same from

2020 to 2021 with a total of (3) cases. In 2019 (11) cases, and (9) cases in 2018. Cases resulting

in medical treatment only but did not result in days away from work or lost time, increased in 2021

resulting in (9) cases. In 2020, total cases resulting in medical treatment was (1) case only. 2019

and 2018 were identical with a total of thirteen (13) cases. The charts shown on the following

pages illustrate this information, and also provide a comparison of the total number of cases for

the past five (5) calendar years as well as total costs incurred each year.

Worker Compensation Claim Count

Worker Compensation Costs by Calendar Year

For calendar year 2021, the majority of PSU claims did not indicate a clear trend. Prior to 2021,

the majority of workers compensation costs resided in the slips, trips and falls category.

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The injury leading to the highest workers’ compensation claim during calendar year 2021 resulted

in a total cost of $58,286. This case accounted for approximately 80% of the total expense

associated with workers’ compensation claims for the year. The injury was sustained while

moving a couch (furniture) to vacuum underneath it. The employee’s shoulder was injured during

this task.

Reviewing the workers compensation costs from 2016 to 2021 illustrated in the above-noted chart,

2016, 2018, and 2021 stand out as higher than average years relative to trends with 2016 and 2021

being the highest. In both of these cases, shoulder injuries were the leading workers compensation

claims. More specifically, in calendar year 2016, the substantial workers compensation cost

increase was the direct result of a shoulder related injury that occurred from a fall. This injury was

responsible for $59,515.44 of the total $82,680.14 in workers compensation costs for that year. In

calendar year 2018, a slip and fall resulted in $36,471.11 of the total $62,850.15 in workers

compensation costs. Lastly, in 2021 a shoulder related injury that occurred while moving furniture

to clean, as stated above, accounted for $58,286 out of the total $71,985 in workers compensation

costs.

The EHS Office and the Human Resources Office continue to work together with PSU’s workers’

compensation insurance carrier, to investigate employee accidents and manage claims. MEMIC

continued as the workers compensation carrier for USNH during calendar year 2021. As noted

above, during 2021, the Human Resource’s Office has been a part of a system wide initiative which

included a restructuring and re-allocation of duties across the USNH system as well as at PSU.

Based on the new organizational structure it is a goal of the EHS Office to meet with the new team

to discuss the continuation of this partnership, and to develop internal processes for notification

and response. During calendar year 2021, as a result of reorganization efforts, a gap in

communication occurred, therefore the EHS Office did not see all accident reports or workers

compensation matters. Meeting and re-aligning duties will help to proactively ensure a continued

partnership in workers compensation efforts.

The Office of Environmental Health and Safety along with the Safety committee continues to

encourage all faculty and staff to report hazards so they can be quickly addressed. As always, the

Facility Services Grounds Department and Building Service Workers respond quickly to any

reports of hazards in an effort to address concerns and/or potentials for injury. Accidents involving

visitors and students continue to be reviewed by the EHS Office, and investigated, as necessary.

Parties to campus investigations include, as applicable, the Office of Environmental Health and

Safety, Human Resources, the affected employee or student, and their respective managers and/or

faculty as needed.

The EHS Office continues to conduct ergonomic evaluations as needed or requested throughout

the year. These evaluations typically result in changes to improve workspaces and ultimately

alleviate existing medical issues or to help mitigate the potential for future concerns for an

individual. During calendar year 2021 no ergonomic evaluations were conducted. This was

largely related to the COVID-19 pandemic. As noted above, throughout the pandemic there were

times of the year where non-essential employees were given the option to work remotely, mainly

during portions of the year when the risk was at the highest, or when students were not living and

learning on campus. Many employees, including those in high-risk categories, were able to

continue to work remotely or balance remote work with in-person schedules until PSU re-opened

for the fall 2022 semester. Over the course of the next year it is likely the campus could see an

increase in ergonomic requests, injuries, strains and/or repetitive use concerns if for no other

reason than a return to normal for on-campus work. Remote work plans eliminate the opportunity

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to manage and modify the workspace of an employee thus resulting in the inability to eliminate

discomfort and potential risk of injury.

In addition, the EHS Office also serves as a liaison with the coordination of campus facility ADA

needs.

During 2021 the were no specific ADA projects completed.

Facilities as well as EHS continued to maintain, install, or improve preventative measures

regarding COVID-19 as needed. While preventive measures in indoor spaces may not be able to

eliminate the risk of COVID-19 transmission entirely, they can help to reduce these risks. The

major push of building changes and adjustments were made during the summer of 2020, to prepare

for a return to on campus living and learning for the fall 2020 semester. Below is a list of the most

notable projects that were implemented in 2020 and then maintained or improved during calendar

year 2021. These projects were based on public health requirements and recommendations.

COVID-19 Building Improvements and Projects – 2020 – Continuation into 2021

▪ Installed (and maintained) plexi-glass barriers in various locations across campus.

Prioritized point of service locations.

▪ Continued to purchase air purifiers for additional spaces based on request, prioritized

areas with no mechanical ventilation.

▪ Maintained (and installed as needed) social distancing and COVID-19 signage across

campus. These included floor marking (indicating 6ft or more distancing), doorway

entrance and exit signage, as well as pedestrian traffic flow and directional management.

This was a joint effort between Facilities and Marketing and Communications. In the

second half of 2021 many of these distancing installations were removed as they were no

longer needed or required based on public health guidelines.

▪ Established new occupancies (COVID-19 and social distancing) for all in person

classroom spaces as well as spaces such as the Hartman Union Building and the Library.

*Beginning in the fall 2021 occupancies were returned to full capacity.

▪ Information Technology Services (ITS) spearheaded remote classroom technology

upgrades across campus for increased remote learning capability during 2020 and

maintained and serviced those installations throughout 2021.

▪ Continued to prioritize residential hall cleaning and disinfection with a campus wide

emphasis on restrooms and high touch high surface areas. Re-directed as needed and

requested based on campus infection rates.

Residential facilities reported, and the EHS Office responded to, occasional reports of bed bugs in

residential facilities during 2021. The EHS Office, Facilities Services, and Residential Life

continue to work closely in prevention and response efforts to these reports. During calendar year

2021 all reports of bed bug problems were acted upon immediately. There was a reduced number

of cases reported during calendar year 2021. Investigations revealed no confirmation of bed bugs

during 2021.

Fall Protection

Fall protection continues to be a priority for Plymouth State University’s Office of Environmental

Health and Safety. In 2018, a written fall protection and roof safety standard operating procedure

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was completed. The full scope of this project was exceptionally complex, requiring a full survey

of facility roofs and the identification of intended fall hazard mitigation strategies. Strategy

considerations included the installation of anchor points, railings, as well as various other means

to mitigate fall potential. The Office of Environmental Health and Safety will continue to partner

with Facility Services to develop a strategic implementation plan identifying cost, need, risk and

a proposed implementation schedule. Future campus projects will incorporate this fall protection

strategy during the architectural phase of planning. Plymouth State University leadership

approvals relative to project implementation and desired outcome for mitigation will be

required/needed.

Confined Space

During calendar year 2020, the EHS Office continued to implement the existing confined space

program, which had undergone an extensive review during 2017. This program includes proper

issuance of the confined space permit and/or alternative entry certificate as needed. PSU’s internal

reporting procedures involve regular communication with the Plymouth Fire Department. Permits

are reviewed and/or completed by the EHS Office.

Lockout Tagout

The Control of Hazardous Energy Lockout/Tagout (LOTO) standard, established by OSHA,

outlines the proper shut down and isolation procedures required prior to conducting any servicing

or maintenance activities. The goal of this program is to securely de-energize a piece of equipment

prior to conducting work and to prevent the equipment from being re-started while the maintenance

or service activity is in progress. PSU has a written LOTO program which underwent extensive

review in 2017. PSU continues to operate via the written program. However, this program should

be one of the programs reviewed by the third-party consultant.

Powered Industrial Trucks

Governance in the use of powered industrial trucks regulated by the OSHA Powered Industrial

Truck Standard, 29 CFR 1910.178, outlines specific operating procedures, training requirements

and inspections. PSU has one powered industrial truck, a forklift, in the Facility Services

Department. PSU has a written procedure specific to industrial truck usage and the completion

of authorized user training is required prior to operating the forklift.

Cranes and Hoists

PSU does not currently own or utilize any cranes or hoists on campus.

RADIATION SAFETY

Radiation Safety has limited applicability at PSU, due to a relative lack of radioactive material.

PSU previously owned three transmission electron microscopes (TEM) that required registration

with the State of NH, Department of Health and Human Services (DHHS), Radiological Health

Section. One TEM, rendered inoperable, remains on site for strictly display purposes inside the

Boyd Science Center. The two remaining TEMs, also rendered inoperable during the summer of

2017, have been removed from campus and properly disposed. All three TEMs have been removed

from the NH DHHS registry.

The PSU Chemistry program acquired an Electron Capture Detector (ECD) during 2017. This

device improves the chemical analytical capabilities of the program and is an important teaching

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tool. This device contains a relatively low activity Nickel 63 (Ni63) source. The ECD requires an

annual wipe test to confirm that no leakage from the device is taking place. Previously, PSU has

utilized the wipe test procedure and conducted this test in place and has previously consulted with

the full-time Radiation Safety Officer at UNH to ensure that proper procedures are being followed.

This was not completed during 2021 and will be a priority to complete in 2022.

FIRE PROTECTION

The EHS office worked with Facilities Staff, as well as Residential Life Staff to ensure that fire

and life safety equipment and programs were maintained during 2021. Efforts continue, in

partnership with the State Fire Marshall’s office, in continuing to conduct annual fire and life

safety inspections of all campus buildings. Inspections are conducted in tandem with the State Fire

Marshall’s Office, the Facilities Department and the local Fire Department. The EHS office

maintains copies of all inspection reports, assembly permits, and certificates of occupancy.

Fire drills are typically conducted each fall in all Residence Halls and Student Apartments. During

calendar year 2021, due to the COVID-19 pandemic, fire drills were not conducted. Absent

unforeseen circumstances, we will resume conducting these drills in the fall of 2023.

The EHS Office has traditionally participated in monthly meetings with the Plymouth Fire Chief

and the State Fire Marshal’s Office. Because a portion of the Plymouth State University campus

is situated in the town of Holderness, the Holderness Fire Chief participates at these meetings as

well when applicable. The purpose of the regularly scheduled meetings is to review campus fire

protection and life safety issues pertaining to projects and campus activities. These meetings were

also affected by the COVID-19 pandemic and were not conducted in person during 2021. Facilities

staff, on behalf of the EHS Office, and in relation to campus specific projects, continued to work

with the local fire departments and the State Fire Marshall’s Office as needed on various projects,

as well as to conduct life safety inspections. During 2022, the EHS Office will work with the state

and local fire agencies to determine if they would like to re-institute these meetings. During 2021,

the longtime Holderness Fire Chief, Eleanor Mardin retired. Chief Mardin had a longstanding

partnership with the University and will be missed. This position was filled by Deputy Chief

Jeremy Bonan, who served on both the Plymouth and Holderness Fire Departments before entering

into the Chief’s position in the town of Holderness.

Fire Marshal Approval-Projects

The EHS Office continues to work alongside management teams within the Facility Services

Department during campus project planning and execution. This allows for input in areas such as

fire, life safety, as well as compliance with the Americans with Disabilities Act (ADA). There

were less projects than previous years due to COVID-19 impacts. Notable projects in 2021,

included but were not limited to:

Building Name Project Completed

Draper & Maynard

Repaired a timber post on the first floor of D&M that

had been rotting below grade causing portions of the

building to settle.

Draper & Maynard

Renovated a portion of the 4th floor in support of the

Electromechanical Technology and Robotics

(EMTR) program.

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Eco House (Diversity House)

Miscellaneous renovations including new roof, porch,

and flooring.

Kelly House

Permitting began in CY 2021 to renovate the space from

administrative to residential. The renovation itself

began in CY 2022.

Boyd Roof

Renovation to a portion of the 4th floor in support of the

Electromechanical Technology and Robotics (EMTR)

program.

Fire/Life Safety Communication

Plymouth State University (PSU) continues fire alarm communication with the use of radio boxes.

In the event of any fire alarm activation, these radio boxes will notify Lakes Region Mutual Aid

and the Plymouth Fire Department will be dispatched. The system completes a self-test daily.

During January of 2015 Plymouth State University received notification from the Plymouth Fire

Department that the antenna tower located on Belknap Mountain collapsed and sustained

significant storm damage. This antenna’s job included sending a radio signal to Lakes Region

Mutual Aid, who then notified the fire department with each fire alarm activation. The antenna

was temporarily relocated in an effort to ensure continued service, not only for PSU, but for other

Lakes Region Mutual Aid customers.

All Plymouth State University radio boxes now transmit their signals to a piece of equipment

located at the Plymouth Fire Department. This unit calls Property Protection Management via

cell phone who then dispatches Plymouth Fire Department for emergency response.

Plymouth State University continues to monitor and maintain the carbon monoxide detection

devices required in some residential areas. At Plymouth State University (PSU), these residential

areas are those having propane fired clothes dryers. These devices were installed in 2012 and

continue to be connected to each building’s fire alarm system. In the event of any carbon monoxide

detection, the alarm will sound within the building and the Plymouth Fire Department will be

dispatched.

OCCUPATIONAL HEALTH AND MEDICINE During 2021, Plymouth State University continued to offer the Hepatitis B vaccination program

to applicable employees. Plymouth State University continues to utilize the declination form as a

way to document employees who decide to opt out of the vaccination program. During 2021

annual Blood Borne Pathogens training did not occur. This will be a priority to complete during

summer of 2022.

The Health and Human Performance Department, the Physical Education Center, Physical Plant,

Health Services Center, and applicable departments within the Hartman Union Building (HUB)

and student life operations, participate in this program.

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INTEGRATED CONTINGENCY PLANNING

Above Ground Storage Tanks & Spill Control & Countermeasure Plan

The PSU main campus has 30 petroleum containers, including: (1) 2,500 gallon oil tank, six (6)

diesel generators, a diesel generator day tank and fire pump, two (2) drum storage areas as well as

nineteen small ASTs used for on-premises heating. All of these above ground storage tanks or oil

storage areas are regulated and registered with NHDES. Additionally, PSU has a co-generation

facility with three larger tanks that currently hold #2 fuel oil. The campus currently maintains two

spill control and countermeasure (SPCC) plans. One for the main campus and one for the co-

generation plant. All written SPCC plans require re-certification, typically by an engineer, once

every five years. Because there were no changes to the Co-Generation Plant’s SPCC plan the EHS

Director was able to self-certify the plan during calendar year 2021 as it was up for re-certification.

Additionally, during 2021 PSU’s main campus continued to operate via the campus Spill

Prevention, Control and Countermeasure (SPCC) Plan. Due to staff turnover, retirements, and the

overall impact of reduced resources surrounding the COVID19 pandemic, not all required above

ground storage tank inspections were completed as required by the plan. A priority of the EHS

Office in 2022 will be to identify and train new staff to complete this requirement.

8.2 Underground Storage Tank Program

PSU has two underground storage tanks located at the PE Center on the Holderness side of

campus. Due to the COVID-19 pandemic underground storage tank (UST) training for tank

operators was put on hold by the NH Department of Environmental Services during 2020 and

part of 2021. This training is required for class A, & B Operators. Training for this program has

resumed in an online format. Training needs to be completed in early 2022 for class A and B

operators. Additionally, new Class B & C operators will need to be identified and trained in

early 2022 as well. As with the AST inspections noted above, due to staff turnover, retirements,

and the overall impact of reduced resources surrounding the COVID19 pandemic, not all

required underground storage tank inspections were completed as required. The goal of the EHS

Office in 2022 is to identify and train new staff to complete this requirement.

9.0 BIOLOGICAL SAFETY

PSU has one Biosafety Level 2 (BSL2) facility in Boyd Science Center, which actively conducts

research using bacteria falling under the BSL2 federal classification category.

During 2019, a formal Institutional Biosafety Committee (IBC) was created by PSU’s Biological

Safety Officer as well as the EHS Office. Creating a formal IBC was a priority for both the EHS

Office and the Biological Safety Officer, Dr. Mike Son. Previously, there had been an informal

committee in place to manage compliance requirements while a formal committee was being

assembled. To become a formal IBC, there is specific committee membership required to meet

the National Institutes of Health (NIH) guidelines. Part of this membership includes two members

of the local community. These individuals are to represent the interests of the community and

surrounding areas with respect to the environmental and public health. Due to the global pandemic

and the restrictions placed on the PSU community, including those surrounding campus access,

the IBC is undergoing a re-establishment of its members, particularly the community members. At

this time, we only have an informal committee until these roles can be filled, which will attempted

to be filled during 2022.

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In addition to the community membership component, the purpose of an IBC, as a whole, is to

ensure that any lab conducting research with, or planning to conduct research with, biological

organisms (i.e. animals, plants, bacteria, fungi, and viruses) or parts thereof (i.e. genetic materials

(DNA/RNA) or proteins) is conducting such research in accordance with guidelines set forth by

both State and Federal legislation. The PSU IBC is currently overseen by PSU’s Biological Safety

Officer, as well as the EHS Office. The formal IBC will begin having meeting(s) as needed and

required. It is anticipated this committee will meet on an annual to semiannual basis. This

requirement will be re-accessed during 2022 so a plan is put in place for calendar year 2023. The

IBC meeting goals were put on hold in 2021 as resources were shifted to meet the needs of the

COVID19 response.

Additionally, since completion of the BSL2 facility, the lab space has been used to conduct both

research activities and course related lab work across two different disciplines – Biological

Sciences (also serving other departments to satisfy student interests) and Nursing. All research

activities have been conducted in accordance with federally funded grants and have led to several

milestones. These milestones include federally funded research activities from July 1, 2013 to

present. Research by the graduate and undergraduate students has led to three peer-reviewed

publications (most recently in 2021) and two book chapters (primarily contributed by the graduate

students), in addition to numerous public presentations, both in poster and oral form, by the

primary faculty member, and his students.

Initial safety, both personal and environmental, has been considered and is strictly enforced

through Plymouth’s current working procedures. These procedures are typically annually

reviewed and modified, if necessary, by the IBC to remain compliant with State and Federal

regulations. With the reprioritization of staff, resources, and responsibilities of COVID-19

response this review did not happen during 2021. This will be reassessed with a target date

assigned during 2022.

Training for all authorized personnel is conducted on a yearly basis, through the CITI training

program for which PSU has registered and is in compliance. This CITI training is currently

monitored/overseen by the Office of Sponsored Programs. In addition, faculty are asked to

continue to practice annual training within each lab, as well as ensuring students and personnel are

also trained through the safety program established by the Geisel School of Medicine at Dartmouth

College, via the NH-INBRE (New Hampshire IDeA (Institutional Development Award) Network

for Biomedical Research Excellence).

In addition to the ongoing research activities, approximately 50 students per academic year, are

trained in the basics of microbiology and research (up to 20 students in fall under the Biology

major, and up to 40 students in spring under the Nursing program). At the start of each semester,

students are introduced to the safety regulations and restrictions of working in a BSL2 facility,

raising public awareness of both State and Federal regulations, but also of the importance of

basic research ongoing at PSU.

DIVING SAFETY

Diving safety was listed as “not applicable” in the Compliance Status “Traffic Light” summary in

the 2017 EHS Report as PSU no longer offers archeology classes involving diving. This continues

to apply for 2020. The only diving activities associated with PSU are four SCUBA classes that

are offered annually as part of Physical Education offerings, two classes in the spring semester,

two classes in the fall semester. These are taught by an adjunct instructor who owns a local dive

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shop. Classes follow protocol set by the SSI (SCUBA Schools International) a worldwide diver

certification agency.

HAZARDOUS MATERIALS/ENVIRONMENTAL MANAGEMENT

Hazardous Waste Management

The EHS Office oversees all hazardous waste activity on campus, including removal, and ensures

the timely inspection of all waste accumulation and storage areas.

The micro scale techniques used in the Boyd Science building continue, resulting in very small

waste streams for most programs. However, as research grants increase and cluster initiatives

develop, it is possible that hazardous waste streams will increase commensurately. During 2021,

the EHS office continued to work with the Science and Art disciplines to ensure all waste streams

are handled properly. Currently both the Plymouth and Holderness campuses are small quantity-

extended generators (SQG) of hazardous waste. Each site has its own separate EPA site number.

While PSU is considered a SQG by the State of NH, a one-time laboratory cleanout in June 2021

resulted in acutely hazardous waste generated at a level that exceeded the Federal Large Quantity

Generator (LQG) threshold. In this instance, PSU was required to submit a biennial hazardous

waste report identifying the waste streams, how they were generated, where they were

transported to, and how they were disposed of.

Although not required for an SQG, PSU historically conducted weekly inspections of

accumulation areas. These inspections were conducted by faculty and staff. Due to the COVID-

19 pandemic and staff turnover, these did not occur in 2020 and 2021. The EHS Office would like

to return to completing these inspections in the fall semester (September 2022). Although not

required, they are proactive and aid in compliance.

In 2021, due to the COVID-19 pandemic, the Director of EHS did not maintain her certification

as a New Hampshire Hazardous Waste Coordinator. This training is not a requirement for small

quantity generators. The purpose of this training is to ensure those who generate hazardous waste

are knowledgeable about the rules and regulations regarding hazardous waste management,

including NH specific hazardous waste rules. This training also meets a Resource Conservation

and Recovery Act (RCRA) annual training. This training is required for those who generate more

than 220 pounds per month of hazardous waste. PSU is currently considered a small quantity

generator (SQG) by the State of NH, generating less than 220 pounds per month of hazardous

waste. This training is a priority during calendar year. Attending this training, although not

required, is a proactive opportunity to maintain knowledge specific to hazardous waste regulations

as well as learning about any potential upcoming regulatory changes.

The University continues to utilize Clean Harbors for hazardous materials and waste disposal.

Clean Harbors provided guidance in assessing potential hazards and aided in regulatory

compliance regarding hazardous waste on campus.

The hazardous waste program will be one that will require review from a EHS consultant during

2022.

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HAZARDOUS MATERIALS INVENTORY AND REPORTING

Chemical Environmental Management System (CEMS)

UNH (developer of the CEMS system) continues to host and maintain the software and data for

Plymouth State University. A continued partnership and extended service agreement for the

CEMS system in place between institutions allows PSU to access safety data sheet information

and gain improved compliance reporting capabilities. Automatic updates managed by UNH via

the service agreement insures up-to-date software tools. Plymouth State’s Office of Environmental

Health and Safety department relies heavily on specific campus liaisons (Art and Science

disciplines) to continue to maintain their portion of the inventory.

The EHS Office continues to monitor the volume and use of numerous chemicals on the US.

Department of Homeland Security’s (US DHS) “Chemicals of Interest” list. If on-hand amounts

exceed pre-set limits, PSU is required to notify US DHS within a specific timeframe.

Given the complexity in nature of the CEMS system and the associated compliance requirements

involved with storing chemicals, inventory verification is a priority initiative for the Office of

Environmental Health and Safety. Phase I of a multi-phase strategic plan involving PSU’s CEMS

system includes the verification and the development of a detailed inventory of all campus

buildings which store and use regulated chemicals. Phase I had been identified as a priority goal

for the department in calendar years 2020 and 2021. However, due to competing priorities during

the COVID-19 pandemic, as well as needing external consultants on site to complete this goal, put

this on hold during the duration of the pandemic. Originally it was the hope of the department to

review this during 2021. However, as the pandemic continued, including the need to plan for

subsequent variants of concern, as referenced in the executive summary, this goal will be re-

assessed during calendar year 2022 with a timeline communicated in 2022’s annal report. Efforts

will focus on identifying those clusters which use and store the largest quantities of chemicals.

Equal attention will focus on clusters storing regulated chemicals despite quantity. Primary

buildings include the Boyd Science Center and its related laboratories, the Draper and Maynard

art building, as well as the Silver Center for the Arts theatre building. Although not an exhaustive

list of buildings needing review, the priority will be to inventory the buildings with the heaviest

usage and storage of regulated chemicals. Future phases of the plan include compliance and

governance relative to all campus material safety data sheets (SDS). Oversight and management

of the CEMS system requires significant resources both physical and financial in nature. The

implementation of Phase I as well as future phases of this initiative will require additional

leadership discussions and possible approvals to ensure the appropriate resources are in place to

complete the goals as outlined.

Air Quality, State Permit to Operate

PSU currently operates air pollutant-emitting equipment under a State Permit to Operate, which

covers our three Co-Generation Plant boilers and nine emergency generators located throughout

campus. The Permit to Operate was renewed with the NH Department of Environmental Service

(NHDES) and was formally issued in March 2019. The renewed permit will be valid for a period

of ten years after the date of issue. As part of the permit renewal process, the University hired an

environmental consulting firm to conduct a third-party audit. This was undertaken to confirm the

University’s compliance with conditions identified in the State Permit to Operate. Additionally,

as part of the air permit requirements, PSU annually quantifies the emissions from each device,

and pays a fee to the New Hampshire Department of Environmental Services based on the total

amount of emissions from campus.

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There was no change to this during 2021.

Emergency Planning & Community Right-to-Know

The Emergency Planning and Community Right to Know Act (EPCRA), is a statute designed to

improve community access to information about chemical hazards, and to facilitate the

development of chemical emergency response plans by the State of NH and local government.

As part of this statue, Plymouth State University is required to complete an annual TIER II

Report by March 1st of each calendar year. This report requires a submittal to the State of NH, as

well as to state and local emergency planning committees (SERCs & LEPCs) including the town

of Plymouth and Holderness fire departments. This report has been completed for 2021 as

required. For reporting year 2020 (submitted in 2021), the table below summaries the TIER II

reporting for the campus over threshold quantities:

Substance Threshold

(pounds)

RY2021 Max

Storage (pounds)

Batteries 10,000 12,979

Sulfuric Acid 500 2,596

Salt 10,000 198,200

Sand 10,000 302,400

#2 Fuel Oil 10,000 513,074

Biofuel (3) 10,000 0

#6 Fuel Oil (1) 10,000 0

Diesel 10,000 13,826

Propane 10,000 68,825

(hydraulic Oil)

Elevators 10,000 25,046

Transformer Oil 10,000 50,252

Compressed Nat. Gas 10,000 48,000

Glycol 10,000 69,709

Waste Ammonia (2) 500 25,147

Wood Pellets 10,000 88,000

CEMS Inventory Varies All Below Reporting

Thresholds

Sulfuric Acid 500 95

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MECHANISMS FOR COMPLIANCE

PSU utilizes several mechanisms to ensure it meets all state and federal requirements, including

the requirements mentioned in this report. Methods include, but are not limited to, publications

and membership in professional organizations such as the American Society of Safety Engineers

(ASSE), Campus Safety, Health, and Environmental Management Association (CSHEMA), and

the Association of Physical Plant Administrators (A.P.P.A.). Formal training and internal

procedures are also utilized to ensure compliance. Regular inspections conducted by local fire

departments and the State Fire Marshal’s Office, combined with regular communication with state

and federal agencies over various matters, also keeps the EHS Office up to date on any new or

upcoming requirements.

The Office of Environmental, Health and Safety was left with a staffing vacancy in May of 2020.

The original goal as to review the EHS Coordinator position for rehire during calendar year 2021.

Due to the ongoing nature of the COVID19 pandemic this was delayed. However, this will be

reviewed during calendar year 2022 with a proposal for PSU cabinet review. If approved, this

position will help to provide additional operational support within the EHS Office.

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* Heat Stress n n

* Illumination n n


















* Dosimetry n n

* Magnet Safety n n

* X-Ray Safety n n


* Laser Safety n n




Not Applicable n


PSU Compliance Status December 2020 and December 2021

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Program Elements 2020 20213.3.3.1.2.4 Occupational Health and Medicine

* Respirator Medical Questionnaire n n















3.3.3.2 Hazardous Materials & Environmental Management3.3.3.2.2.1 Hazardous Waste Management

* Hazardous Waste Management Program n n







3.3.3.2.2.2 Hazardous Materials Inventory and Reporting

* Chemical Environmental Mgmt System/Inventory System n n













Annual Report - December 2020PSU Compliance Status December 2020 and December 2021


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2021 Annual Report for the UNH Office of Environmental Health and Safety

2021 Annual Report for the

Office of Environmental Health & Safety

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Table of Contents

1.0 Major Accomplishments 1

2.0 Mission Statement 3

3.0 Vision Statement 3

4.0 Core Values 4

5.0 Campus Program Elements and Objectives 5

6.0 Injury and Illness Prevention 5

6.1 Industrial Hygiene 5

6.1.1 Hazardous Building Materials 7

6.2 Injury Prevention 8

6.3 Indoor Environmental Quality 10

6.4 Occupational Safety 11

6.4.1 Confined Space Entry 12

6.4.2 Fall Protection 13

6.4.3 The Control of Hazardous Energy (Lockout/Tagout) 14

6.4.4 Powered Industrial Trucks 14

6.4.5 Cranes and Hoists 15

6.4.6 Mobile Elevating Platforms (formerly Aerial/Scissor Lifts) 15

6.4.7 Workplace Safety Inspections 16

6.4.8 Hearing Conservation 16

6.4.9 Respiratory Protection 17

6.4.10 Hazard Communication 17

6.4.11 Hot Work/Welding Safety 18

6.4.12 Construction Safety 19

6.4.13 Occupational Safety Committee 19

6.5 Safety Training and Education 19

6.6 Ergonomics Programs 20

6.7 Occupational Health Medicine 22

6.8 Emergency Procedures 23

6.8.1 Emergency Procedures Program 23

7.0 Diving Safety 23

8.0 Disaster and Emergency Preparedness 26

8.1 Integrated Contingency Plan 26

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8.2 Spill Prevention Control and Countermeasure (SPCC) Planning 28

8.3 Emergency Planning and Community Right‐to‐Know 29

9.0 Environmental Monitoring 31

9.1 Air Quality 31

9.1.1 Title V Air Permit 31

9.1.2 Air Toxics 31

9.1.3 Refrigerant Management Program 33

9.2 Impacted Soils Management – Urban Fill 33

10.0 Laboratory Safety 34

10.1 Biological Safety 34

10.1.1 Institutional Biosafety Committee Use of Cayuse Hazard Safety Software 34

10.1.2 Institutional Biosafety Committee 34

10.1.3 Engineering Controls 37

10.1.4 Autoclave Treatment of Biohazardous Waste___________________________________________37

10.1.5 Institutional Animal Care and Use Committee 38

10.1.6 Bloodborne Pathogens Program 38

10.1.7 Biosecurity 39

10.1.8 Training 39

10.2 Chemical and Laboratory Safety 39

10.2.1 Laboratory Safety Inspections 39

10.2.2 Chemical Safety Committee 40

10.2.3 Regulatory Compliance Services 40

10.2.4 Chemical Fume Hood and Laboratory Ventilation Assessments 40

10.2.5 Laboratory Design and Renovation 42

10.2.6 Laboratory Safety Technical Services 42

10.2.7 Laboratory Safety Training 43

11.0 Hazardous Materials 44

11.1 Chemical Transfer Station 44

11.2 Chemical Inventory Validation Program 45

11.3 UNHCEMS® Inventory 45

11.4 Hazardous Materials Shipping 46

11.5 Hazardous Waste Management 47

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11.5.1 Inventory Reductions 47

11.5.2 Summary of Hazardous and Universal Wastes Generated 48

11.5.3 Universal Waste 50

12.0 Radiation, Laser and Magnet Safety 54

12.1 Radiation Safety 54

12.1.1 Program Information 54

12.1.2 Training 55

12.1.3 Radiation Protection Program Maintenance 55

12.1.4 Audit and Regulatory Review 55

Third Party Audit 55

12.1.5 Radiation Safety Monitoring Instruments 55

12.1.6 Occupational and Public Doses 56

Dosimetry Program 56

12.1.7 Surveys and Monitoring 57

12.1.8 Leak Test Procedures 57

12.1.9 Waste Management 57

12.1.11 Waste Minimization 58

12.1.12 Radon Management Program 58

12.2 Magnet Safety 58

12.2.1 Program Information 58

12.2.2 Training 58

12.2.3 Registration and Instrumentation 59

12.2.4 Surveys and Audits 60

12.2.5 Program Maintenance 60

12.3 X‐Ray Safety 60

12.3.1 Program information 60

12.3.2 Training 60

12.3.3 Registration and Instrumentation 61

12.3.4 Surveys 61

12.3.5 Postings 61

12.3.6 Audits and Regulatory Reviews 62


12.4 Laser Safety 62

12.4.1 Program information 62

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12.4.2 Training 63

12.4.3 Registration and Inventory 63

12.4.4 Standard Operating Procedures 63

12.4.5 Personal Protective Equipment 64

12.4.6 Surveys 64

12.4.7 Audits 64


13.0 UNH at Manchester 64

13.1 Safety Committee 64

13.2 UNHCEMS® ‐ Chemical Inventory and Training 65

13.3 Contingency Planning 66

14.0 UNH School of Law 66

14.1 Emergency Health and Safety Committee 66

14.2 Other Accomplishments 67

15.0 Emerging Issues 67

15.1 COVID‐19 Management and Response 67

15.2 UNH at Manchester Incubator Facility 67

15.3 UNH Ice Rink Upgrades 68

15.4 UNHCEMS® 3.0 Development 68

16.0 Communication and Outreach 68

17.0 Mechanisms to Measure Compliance 69

17.1 Industrial Hygiene 69

17.2 General Safety 69

17.3 Fire Protection 69

17.4 Occupational Health and Medicine 69

17.5 Disaster Preparedness 70

17.6 Diving Safety 70

17.7 Biological Safety 70

17.8 Hazardous Materials Inventory and Reporting 70

17.9 Hazardous Waste Management 70

17.10 Radiation Safety 70

17.11 Laboratory Safety 71

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Acronyms

AAL Ambient Air Limits

ABSL-1 Animal Biosafety Level 1

ACGIH American Conference of Governmental Industrial Hygienists

ACM Asbestos Containing Material

ALARA As Low As Reasonably Achievable

ANSI American National Standards Institute

AST Aboveground Storage Tank

BIC Biotechnology Innovation Center

BSL-1 Biosafety Level 1

BSL-2 Biosafety Level 2

CAAA Clean Air Act Amendments

CEPS College of Engineering and Physical Sciences

CFATS Chemical Facility Anti-Terrorism Standards

CFR Code of Federal Regulations

CHWAA Central Hazardous Waste Accumulation Area

CLIA Clinical Laboratory Improvement Amendments of 1988

COLSA College of Life Sciences and Agriculture

CSC Chemical Safety Committee

CTS Chemical Transfer Station

DAW Dry Active Waste

DFD Durham Fire Department

DHS Department of Homeland Security

DIS Decay-in-Store

DNA Deoxy Ribonucleic Acid

DOT Department of Transportation

EHSC Emergency Health and Safety Committee

EH&S Environmental Health & Safety

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Acronyms (Continued)

EPCRA Emergency Planning and Community Right to Know Act

EPP Emergency Procedures Program

GC Gas Chromatograph

HR Human Resources

HVAC Heating Ventilation and Air Conditioning

IACUC Institutional Animal Care and Use Committee

IAQ Indoor Air Quality

IBC Institutional Biosafety Committee

ICP Integrated Contingency Plan

IEQ Indoor Environmental Quality

LED Light Emitting Diode

LEPC Local Emergency Planning Committee/Coordinator

LPG Liquefied Propane Gas

LSC Liquid Scintillation Counter

LSII Laboratory Safety Inspection Initiative

LSP Laser Safety Program

MCBS Molecular, Cellular, and Biological Science

MOD-rate Experience Modification Rate

MSP Magnet Safety Program

NHDES New Hampshire Department of Environmental Services

NHVDL New Hampshire Veterinary Diagnostic Laboratory

NMR Nuclear Magnetic Resonance

ODS Ozone Depleting Substances

OEHS Office of Environmental Health and Safety

OSHA Occupational Safety and Health Administration

PCBs Polychlorinated Biphenyls

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Acronyms (Continued) PE Professional Engineer

PEL Permissible Exposure Limit

PIs Principal Investigators

PIT Powered Industrial Truck

PPE Personal Protective Equipment

PSA Public Service Announcement

RMP Refrigerant Management Program

RNA Ribonucleic Acid

RPP Radiation Protection Program

RSO Radiation Safety Officer

RSC Radiation Safety Committee

RSUG Radiation Safety Users Guide

RTAP Regulated Toxic Air Pollutants

SARA Superfund Amendments and Reauthorization Act

SCUBA Self-contained Underwater Breathing Apparatus

SDS Safety Data Sheets

SERC State Emergency Planning Coordinator/Committee

SM Superconducting Magnet

SOP Standard Operating Procedure

SPCC Spill Prevention Control and Countermeasure Plan

UIC University Instrumentation Center

UNH University of New Hampshire

UNHCEMS® University of New Hampshire Chemical Environmental Management System

UNH-M University of New Hampshire at Manchester

UNH PD University of New Hampshire Police Department

US EPA United States Environmental Protection Agency

USNH University System of New Hampshire

XPP X-ray Protection Program

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2021 Annual Report for the UNH Office of Environmental Health and Safety 1

1.0 Major Accomplishments


Hampshire Department of Environmental Services (NHDES) performed a comprehensive hazardous waste compliance inspection at UNH Durham in June, 2021. The final report of the inspection identified no pending action items and no penalties. Inspectors noted at the time of the inspection that UNH has the most complex hazardous waste management program in the state. Achieving this level of compliance is a clear indication of UNH’s cultural commitment to safety and environmental stewardship.

Cayuse Hazard Safety Software Design and Roll-Out for Institutional Biosafety Committee

The Research Office purchased a software (Cayuse) for managing research grant awards and many regulatory aspects that go along with grant compliance. One of those aspects is compliance with the National Institutes of Health Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules and oversight by the Institutional Biosafety Committee. EH&S participated in software design, development of supporting materials and implemented a “soft” roll out, with Principal Investigators adding new and renewal protocols into the system as they come up for expiration. Protocol transfer from the UNHCEMS® system to Cayuse IBC will be completed in 2021. Stillings Hall MMIP Approval

During the fall of 2019, OEHS conducted its annual Monitoring Maintenance and Implementation Plan (MMIP) for Stillings Hall in accordance with the 2010 conditional approval granted by the United States Environmental Protection Agency (EPA) for the removal of windows and associated caulking that contained polychlorinated biphenyls (PCBs). An exceedance was detected during the 2019 surface wipe sampling that required notification to the USEPA and the development of a mitigation plan. The mitigation plan was reviewed by the EPA where they indicated that the current air monitoring action level, which was within the EPA Public Health Levels of PCBs in School Indoor Air, was not protective enough. In 2021 OEHS worked with an environmental engineering firm to request that the EPA revise the proposed action level; EPA approved the request and was granted final approval for the revised MMIP.

Research Environmental Growth Chamber Support

OEHS convened a group of technical experts to provide support designing a research environmental growth chamber for use with isotopically labeled carbon. Initial design draft design exhibited issues related to chemical safety and electrical safety. Through a collaborative evaluation process, issues were mitigated, greatly improving researcher safety. Chemical and electrical safety were main considerations in design discussions.

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Broad Scope License Renewal

OEHS applied with the State of NH for full renewal of its broad scope license for radioactive material use. The broad scope license enables UNH to work with a diverse number of radioactive materials with a high degree of autonomy but requires a comprehensive radiation safety program and active radiation safety committee to receive approval. UNH fulfilled the rigorous state requirements to be granted the broad scope license.


New Hampshire Department of Environmental Services (NHDES) performed a comprehensive hazardous waste compliance inspection at UNH Durham in June, 2021. The final report of the inspection identified no pending action items and no penalties. Inspectors noted at the time of the inspection that UNH has the most complex hazardous waste management program in the state. Achieving this level of compliance is a clear indication of UNH’s cultural commitment to safety and environmental stewardship.

Radioactive Material Source Reduction

OEHS worked with UNH researchers to schedule decommissioning of three liquid scintillation counters. Liquid scintillation counters are used to quantify radioactive materials in research samples and contain a radioactive source. The equipment had become unsupported by the manufacturer, so their value as a research tool was limited. By safely decommissioning the obsolete equipment, UNH reduced risks associated with managing the radioactive material in the equipment.

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2.0 Mission Statement

The UNH OEHS works to ensure safe and healthful environments for all segments of the campus population, through programs of information and education, review and monitoring, technical consultation, and provision of direct services. OEHS is also responsible for developing programs to ensure compliance with applicable state and federal health, safety and environmental regulations, and campus policies on environmental health and safety. Areas of responsibility include hazardous materials, environmental management, and injury and illness prevention as highlighted in the University System of New Hampshire (USNH) Policy on Environmental Health and Safety. The protection of human health and compliance with applicable regulations are essential conditions for the successful operation of research, conduct of instruction, and provision of public service by the University. OEHS supports the University of New Hampshire’s mission by providing leadership, resources, and services to assure a safe and healthful working environment for all members of the University and its surrounding community.

3.0 Vision Statement

OEHS will be a valued partner in the creation and maintenance of a safe and healthy University environment and will achieve excellence through its provision of leadership, oversight, stewardship, and services.

4.0 Core Values OEHS has adopted a Code of Professional Conduct. These core values describe the standards to which we aspire. They guide our actions and help to assure accountability, responsibility and trust as we interact with one another and our campus clients.

Excellence: We dedicate ourselves to the highest standards of quality in our professional work, outreach, public service, mentoring, and advising.

Integrity: We commit ourselves to an open, honest, and trustworthy approach to all endeavors we are working on. We value fairness, straightforward conduct, adherence to the facts, sincerity and transparency. We will make a reasonable effort to provide appropriate professional referrals when unable to provide competent professional assistance.

Responsiveness: We respond to and address the needs and expectations of our students, faculty, staff, partners, and external constituents.

Respect: We foster an environment of mutual respect. We listen to each other, encourage each other and care about each other.

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Diversity: We commit to an inclusive community for diverse students, faculty and staff. We reject bigotry, oppression, degradation and harassment, and we challenge injustice toward any member of our community.

Accountability: We are personally and organization ally accountable for all that we do and commit to providing timely and comprehensive evaluation of our programs and efforts.

Figure 1: UNH Wildcat Statue located in front of Whittemore Arena

Innovation: We want to be at the forefront of change and believe that the best way to lead is to learn from our successes and mistakes and continue to grow. We are forward-looking and break new ground in addressing important community and societal needs.

Openness: We encourage the open exchange of information and ideas from all quarters of the university community. We believe that through collaboration and participation, each of us has an important role in determining the direction and well-being of our community.

5.0 Campus Program Elements and Objectives

UNH has adopted an Environmental Health and Safety Mission Statement that works to assure safe and healthful environments for all segments of the campus population, through programs of information and education, review and monitoring, technical consultation, and provision of direct services. OEHS has developed and implemented programs to ensure compliance with applicable state and federal health, safety and environmental regulations, and USNH policies on environmental health and safety. 6.0 Injury and Illness Prevention

6.1 Industrial Hygiene

Industrial hygiene is the art and science of the recognition, evaluation, and control of those environmental factors or stresses, arising in or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort and inefficiency among workers or citizens of the community. OEHS performs worksite assessments to determine potential health

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hazards throughout the many locations associated with UNH and manages the campus Respiratory Protection and Hearing Conservation programs. Technical assistance is provided on issues involving chemical hazards that can contribute to exposure risks (including laboratory exposures), exposures as the result of chemical release incidents, noise, heat, and hazardous building materials. Advice is provided on protective measures that include the development and implementation of corrective controls or the use of personal protective equipment (PPE).

OEHS calibrates and maintains an inventory of thirty (30) direct reading/sampling instruments (Table 1).

Table 1 Direct Reading Instruments and Sampling Pumps Maintained by OEHS

Instrument Make (# devices)

Model

Use Type

Calibration Frequency

Jerome (1) 431-X Mercury vapor analyzer

Annual factory calibration, operation verified weekly

Sensidyne (5) Gil-Air 3 Personal air sampler Prior to and following use Gillian (8) BDX Personal air sampler Prior to and following use RAE Systems (1)

MiniRae 2000

Photoionization detector

As-necessary, calibration verified weekly

Industrial Scientific (1)

Ventis MX-4

Multi-gas monitor As-necessary, calibration verified weekly

Aeroqual (1) Series 200

Ozone monitor Annual factory calibration, operation verified weekly

Aeroqual (1) Series 200 Dust Monitor Annual factory calibration, operation verified weekly

Allegro Industries (2)

Rotary Vane Sampling Pump

High volume air sampling

Prior to and following use

Simpson (1) 884-2 Sound level meter Annual factory calibration, checked before use

TSI (1) P-Trak Ultrafine particle analyzer

Annual factory calibration, operation verified weekly

TSI (2) Q-Trak with 966 (3 total) and 982 (2 total) probes

Indoor air quality, air velocity

Annual factory calibration, calibration verified weekly

TSI (1) 9565-A Air velocity Annual factory calibration Quest 3M (1) QT-32 Heat stress monitor Annual factory calibration General (1) MMD900 Moisture meter As-necessary, checked before use Casella (3) dBadge2 Noise dosimeter Prior to use

These instruments provide information relative to airborne constituents such as lead, asbestos, mold, particulates, and specific airborne chemicals.

OEHS responded to twenty-five (25) requests from the campus community for industrial hygiene

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technical services in 2021. Inquiries were related to hazardous building materials, potential exposures to hazardous chemicals, heat, and noise.

Throughout the 2021 calendar year OEHS continued its efforts to evaluate potential hazardous exposures on campus for a variety of departments. These efforts included:

• An assessment of the Makerspace 3D SLP printer and proposed new laser cutter.

• The evaluation of potential noise sources at the Olson Manufacturing Center. Multiple operations were observed to create elevated noise levels such as the water jet cutter and shop equipment.

• A review of reproductive hazards for graduate students conducting research in James Hall.

• A review of multiple safety data sheets to evaluate potential risks during the use of hazardous chemicals during cleaning, sanitization, and floor servicing by Housing/Housekeeping. In addition, the review allowed for the proper selection of personal protective equipment for use by those handling and using chemical materials.

• Researching and reviewing data on particulate and poor air quality outside and providing guidance for the Kinesiology departments cardiac workout sessions, the result of western wildfires that impacted the northeast.

During the summer months, OEHS monitors the weather to support the UNH Excessive Heat Advisory Program (see UNH On-Line Policy Manual, UNH VD 3.5). A 3M QUESTemp wet-bulb globe thermometer (Figure 2) is placed outside to measure the outdoor heat. When the outdoor temperature exceeds the consensus threshold for heat as established by the American Conference of Governmental Industrial Hygienists, OEHS will issue a heat advisory for the campus. The Heat Advisory contains a prescription of work and rest for those employees, athletes, visitors, and/or guests who may be working outside, and, as necessary, for those working inside. OEHS issued a total of six (6) heat advisories throughout 2021, down one from the seven (7) advisories that were issues in 2020.

Figure 2: Quest Wet Bulb Globe Thermometer used by OEHS to monitor weather for health advisories

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6.1.1 Hazardous Building Materials

Hazardous building materials can be present in several forms throughout UNH campus buildings. Fortunately, the presence of these materials does not constitute a risk for occupants as long as the materials are maintained in good condition and their condition monitored on a regular basis. To assist in maintaining these materials OEHS oversees the Hazardous Building Materials Operations & Maintenance Manual that incorporates programs to manage the three more commonly associated materials: asbestos; lead; and polychlorinated biphenyls (PCB).

OEHS has been formally assessing all campus buildings for the presence of asbestos containing materials (ACM) and lead based paint since 2011. The assessment project was designed to identify suspected materials, and document their locations, quantities, and condition (see Figure

3). All known materials identified during the surveys are entered into UNH FAMIS and printed on work orders to alert Facilities personnel of the materials presence. FAMIS is an electronic asset management system utilized by UNH Facilities personnel for work orders and asset maintenance. In addition to the work orders, all employees whose jobs could put them in contact with ACM are required to participate in annual Asbestos Awareness training. This includes Housekeeping, Facilities Operations, Telecommunications, Facilities Project Management, and Housing. In 2021 OEHS conducted surveys for five campus buildings that include the Farm Machinery Building, Grounds and Events, Fish Hatchery, Central Heating/CoGen Plant, and the Browne Center, bringing to date a total of 86 campus buildings that have been formally surveyed for the presence of asbestos and lead with the respective data entered into FAMIS. During 2021 OEHS worked with Facilities Information Technologies to transition the inclusion of information from FAMIS into AIM, a new asset management system implemented by Facilities.

The Asbestos Operations & Maintenance Plan establishes responsibilities for specific operating groups that could encounter ACM as part of routine operations. The plan also outlines inspection procedures and frequencies, emergency procedures to follow in the event of a fiber release, and training requirements. Employees whose daily work routine requires possible contact with ACM, or who have related responsibilities are required to attend 2-hour Asbestos Awareness Training. In 2021, 71 employees participated in the 2-hour Asbestos Awareness training. To ensure identified materials are maintained in good condition, OEHS conducts visual inspections of all areas where known ACM are present. The conditions are documented annually, and each inspection record is maintained at OEHS. Copies of all inspections along with any recommendations are forwarded to the respective operating group responsible for the inspected building/area.

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Figure 3: Example of flooring material that is known ACM located in the Iddles wing of Spaulding Hall

More recently, the presence of PCBs in caulking has created unique challenges for building renovation and/or demolition activities. Part of the Hazardous Building Materials Operations and Maintenance Manual includes the Caulking Management Plan. This plan was developed to outline specific procedures to be followed prior to and during construction-related projects where caulking materials may be impacted. In addition, the plan outlines additional procedures to be followed should caulking need to be impacted in an emergency (i.e. repair of a broken window).

OEHS works closely with Facilities Project Management during projects that require the abatement of lead, asbestos, or PCBs. Work involving abatement requires specific training and experience. To ensure only those qualified firms conduct hazardous building materials, OEHS, along with USNH Procurement Services, have approved term contractors for abatement, environmental engineering, industrial hygiene, and project oversite.

OEHS manages two PCB Monitoring, Maintenance, and Implementation Plans (MMIP) that were established as part of conditional approvals by the United States Environmental Protection Agency (USEPA) for the removal and replacement of windows associated with Stillings Hall and the Field House. Under each conditional approval, UNH is required to monitor locations where PCB contamination remains on an annual basis. The monitoring under each MMIP involves a visual assessment of each window for substrate damage, and the collection of air and wipe samples to evaluate the effectiveness of applied engineering controls.

6.2 Injury Prevention

The effectiveness of a safety program can be assessed in many ways. However, it is typically reviewed from a financial perspective. UNH losses are analyzed by OEHS to evaluate the frequency (number of incidents) and the severity (cost associated with an injury). OEHS, in conjunction with UNH Human Resources (HR) and our Workers Compensation Insurance Carrier, Maine Employer’s Mutual Insurance Company (MEMIC) monitors monthly trends and costs and

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works to focus efforts on addressing those areas where a higher frequency and/or severity of accidents are occurring.

In 2021 UNH reported 181 incidents with 69 being compensable. A summary of the 2021 losses compared to the previous two years is provided in Table 2 below.

Table 2 Comparison of 2021 versus 2020 Losses

Year Total

Reported

Net Paid Out

Reserves

Incurred Costs

2021 181 $163,000 $143,000 $306,000

2020 171 $105,000 $65,000 $170,000

2019 293 $301,000 $142,000 $443,000 NOTE: Financial losses are reported as incurred costs that include both the actual costs paid to date (Net) and any potential future costs and reserves (Reserves). Actual losses can fluctuate both up and down based on the claim and settlement.

As summarized in Table 2, 181 incidents were reported through the online UNH chemical and environmental management system (UNHCEMS®) to the OEHS staff and HR, of which 57 were report-only (meaning no significant injuries or medical treatment was required and therefore non- compensable). Of the remaining 124 reported incidents, 55 required basic first aid and 61 required medical treatment. As a result, the compensable injuries yielded approximately $306,000 in losses. These numbers are up when compared to 2020 where UNH experienced 171 incidents that resulted in approximately $170,000 in financial losses. This is a 6% increase in total reported incidents and a 56% increase in losses. Figure 4 summarizes UNH claims and monetary losses for the previous thirteen years.

Figure 4: Total workers compensation claims versus losses paid over last 15 years at UNH.

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It must be noted that financial losses are reported as incurred costs that include both the actual costs paid to date and any potential future costs and reserves. Actual losses can fluctuate both up and down based on the claim and settlement. The sum of total paid losses for 2021 are approximately $163,000 with an approximate $143,000 being held in reserves.

A second means to evaluate the effectiveness of an existing safety program is reviewing the experience modification rate (MOD-rate). The MOD-rate is a multiplier provided by the National Council on Compensation Insurance (NCCI) that is applied to an employer’s workers compensation insurance premium. An employer with a strong safety record will have a MOD-rate of under 1 reducing the actual cost of insurance while those with weak safety records will have a MOD-rate in excess of 1. UNH’s MOD-rate in 2021 was reported by NCCI as 0.70 which is slightly lower than 2020 when it was reported as 0.78.

OEHS conducts routine accident investigations to determine the root cause of an accident and develop corrective actions as necessary to prevent a reoccurrence. Many investigations involve a simple telephone call or e-mail requesting information on recommended corrective actions while more frequent or significant accidents involve a more formal site visit, interviews, and assistance from various operating groups. These are followed up with a more formal investigation report. In 2021 OEHS conducted 12 formal investigations. 6.3 Indoor Environmental Quality OEHS investigates indoor environmental quality (IEQ) complaints and concerns filed by campus community members. While most complaints involve thermal comfort, odors, or non-specific symptoms, some are associated with reports of microbiological contamination/growth, specific health-related symptoms related to indoor air, or response to a water intrusion. Indoor Air Quality (IAQ) surveys and due diligence assessments are conducted following routinely practiced industry standards for the investigation of IEQ complaints. OEHS manages the UNH Indoor Air Quality Management Plan and conducts/coordinates evaluations; maintains two direct reading instruments to monitor basic IEQ parameters, two moisture survey meters to evaluate for damp conditions that can be conducive for microbiological growth, and an ultrafine particle analyzer (Figure 5) that can be used to assess for dusts/particles and determine their source.

Figure 5: TSI Q-Track IAQ Monitor, General Moisture Meter, TSI P-Trak Ultrafine Particulate Counter

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In 2021, OEHS responded to seventy-six (76) requests for IEQ services, up from the forty-

four(44) in 2020 (Figure 6). Three (3) request required remediation or corrective actions while

OEHS requested assistance from IAQ consultants on five (5) occasions. Remedial efforts were

funded primarily by the affected departments while the external sampling efforts were funded

through the Environmental Health & Safety (EH&S) Mitigation Fund established in 2009.During

2021 OEHS saw a significant increase in the number of mold concerns in dorms. Of the 76 IAQ

complaints, 45 were directly associated with concerns related to mold in UNH dorms. While most

of the concerns did not identify a source of mold, 4 buildings underwent cleaning to remove

microbial contamination.

Figure 6: Indoor Environmental Quality Requests Received by OEHS from 2011 through 2021

6.4 Occupational Safety

The safety programs at UNH focus efforts on injury prevention through the development and implementation of policies and procedures for the recognition and identification of hazards and the development of corrective actions. OEHS works with campus stakeholders on issues of safety to assist in assuring compliance with applicable regulations, regulatory interpretation, and by providing technical assistance. In 2021, OEHS responded to thirty-seven (37) requests for technical assistance on a broad range of safety topics including: walking and working surfaces; respiratory protection; PPE; cranes and hoists, contractor safety; fire safety and prevention; emergency action planning; confined space entry; fall protection; the control of hazardous energy (lockout/tagout); welding and cutting; fuel handling; electrical safety; powered industrial trucks; and Mobile Elevating Work Platforms (MEWP). This is up when compared to twenty-five requests in 2020.

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OEHS conducted an annual review of each of its thirteen written Occupational Safety Programs in 2021 to address any regulatory changes in the programs and for any operational questions or concerns from impacted campus representatives. The following documents are reviewed and maintained by OEHS Occupational Safety:

• Respiratory Protection Program

• Hearing Conservation Program

• Lockout/Tagout

• Hot Work Permit

• Confined Space Entry

• Powered Industrial Trucks

• ACM Operations and Maintenance Plan

• Fall Protection

• Crane & Hoist Safety Program

• Caulking Management Program

• Hazard Communication Program

• Indoor Air Quality Management Plan

• Mobile Elevating Work Platform (formerly Aerial Lift Safety Program)

6.4.1 Confined Space Entry

The UNH Confined Space Entry Program is designed to outline specific requirements and procedures to allow employees to safely enter and conduct work in spaces that have been identified, as permit required confined spaces. These procedures include training, air monitoring, the use of specific equipment to facilitate non-entry rescue, and the use of a permit entry system. OEHS receives, reviews, and maintains all permits for activities involving entry into UNH confined spaces. Figure 7, below, is an example of a confined space at UNH.

In 2021, OEHS received seventeen (17) confined space entry permits. Permits are reviewed and if necessary, field verified on campus to ensure personnel are entering following current UNH program requirements. In addition, permits are reviewed with each applicable operating group as part of the annual program review and assessment. OEHS and UNH continue to partner with the Durham Fire Department (DFD) to provide confined space entry rescue services.

Figure 7: Equipment identified as a Permit Required Confined Spaces

OEHS has identified and inventoried 625 confined spaces on the UNH Durham campus. Recent demolition/renovation activities on campus have reduced the number of spaces down from 641 in 2020. These spaces include sewer manholes, tanks, pits, and vaults. The UNH Confined Space Inventory is managed in the Confined Space Inventory Database (CSID) accessed from the UNH OEHS web site. As part of the CSID trained employees and contractors can access information regarding the hazards of identified spaces, complete, and submit entry permits electronically.

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In 2021 OEHS was contacted by Campus Energy and Facilities to evaluate entry procedures into the wood chip vault located within the Northwest Heating Plant. The space had no provisions for entrants for fall protection and non-entry rescue. OEHS worked with those responsible for entry into the vault and an outside engineering firm to design and install the appropriate safety devices. This was completed in the fall of 2021. During 2021 OEHS worked with faculty and students in the Environmental/Civil Engineering department to safely access sewer manholes as part of their research on COVID and waste streams. OEHS evaluated each space prior to, and during opening to monitor for combustible vapors and hydrogen sulfide. This was conducted during waste stream sampling and dye testing.

6.4.2 Fall Protection

OSHA requires that any employee exposed to a fall of four (4) feet or more be protected by means of protective measures. Fall hazards exist for any employee required to work on, in, or near roof systems, aerial lifts, scissor lifts, scaffolding, unprotected attic spaces, open pits, floor holes, or elevated walkways and platforms. The UNH Fall Protection Program outlines specific controls to be utilized when fall hazards exist. While the OSHA fall protection standards (29 CFR 1926, Subpart M and 29 CFR 1910, Subpart D) specify three methods to protect employees from falls; safety nets, the use of guardrails, and/or personal fall arrest systems; the UNH program recognizes only two, the use of guardrails and personal fall arrest systems. As part of the program OEHS conducts annual documented inspections of approximately 100 full body harnesses and lanyards located on campus that are used as part of a personal fall arrest system to protect employees against falls from elevated surfaces. Employees exposed to fall hazards receive training on the recognition of fall hazards and the use of protective systems.

In 2021 OEHS was involved in the review and design for a fall protective system for the new Health Sciences Simulation Center. Figure 8 shows an example of a fall protective system installed on Kingsbury Hall.

Figure 8: Guardrails installed on the roof of Kingsbury Hall

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6.4.3 The Control of Hazardous Energy (Lockout/Tagout)

Lockout/Tagout can be defined as the complete physical isolation of all energy sources associated with a piece of equipment or machinery to ensure an employee conducting servicing or maintenance is not exposed to any hazardous energy sources through the accidental startup of the equipment or machinery or release of stored energy. To achieve this, OSHA has established its Control of Hazardous Energy (Lockout/Tagout Standard) 29 CFR 1910.147. To ensure UNH Compliance with the OSHA standard, the UNH Lockout/Tagout Program outlines the proper shut down and isolation procedures required prior to any servicing or maintenance activities. Employees conducting servicing or maintenance must identify all hazardous energy sources and once identified, they are shut down and physically isolated by the application of a lock on the isolation device (lockout). In addition, each lock is required to have a tag applied to it (tagout) that clearly specifies not to remove as lockout/tagout taking place. Each applied lock and tag is to be applied by each person conducting servicing or maintenance on each energy source required to be isolated. The UNH Lockout/Tagout program applies to all UNH employees to some degree. The selected Facilities personnel that would be required to shut off equipment and/or machinery and conduct servicing or maintenance activities are considered authorized employees and receive specific training on the program elements. All other employees are considered affected as the work an authorized employee conducts could at any time affect anyone.

6.4.4 Powered Industrial Trucks

The UNH Powered Industrial Truck (PIT) Program outlines the practices and procedures to ensure the safe use and operation of PITs at UNH, formalize the required inspections, and outline specific training requirements for those required to operate them. PITs are a valuable tool for material handling, buttheir use is not without risk. The OSHA Powered Industrial Truck standard, 29 CFR 1910.178 outlines specific requirements employers must follow to ensure their safe use. UNH currently has an inventory of thirteen (13) PITs that encompass three of the seven truck classes. They include two class II trucks that are used in Facilities Warehousing (Figure 9) and Chase Ocean Engineering, seven class III powered hand jacks that are used in Facilities Warehousing and Dining Services, and four class V trucks that are used in Facilities Warehousing, College of Engineering & Physical Sciences (CEPS), Campus Recreation, and the Coastal Marine Center. The class of PIT is designated based on their use and fuel source. Nine of the PITs at UNH are battery powered, three are powered by liquefied propane gas (LPG), while one is diesel fuel operated. Each class has specific operational characteristics, fueling/charging requirements, and inspection criteria that must be followed. In addition, training is required to include both formal instructions, practical hands-on training, and is complete when each operator successfully passes an operator evaluation for each PIT they would be required to operate. The PIT program standardizes how each truck is managed, including training and inspections.

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Figure 9: Typical Powered Industrial Truck in use at UNH

6.4.5 Cranes and Hoists

UNH currently has an inventory of thirty (30) operational cranes and hoists that service a variety of programs and departments on campus. They include the largest crane, a 10-ton bridge crane in Kingsbury Hall, to smaller cranes and hoists used by Facilities, the Dairy Farm, Jackson Estuarine Laboratory, and the Coastal Marine Center in New Castle New Hampshire. During 2021 UNH acquired five 5-ton bridge cranes at the Olson Manufacturing Center while two hoists were installed at the new Water Treatment Facility. Formal training requirements, inspection procedures, and responsibilities are outlined in the UNH Crane and Hoist Safety program.

6.4.6 Mobile Elevating Platforms (formerly Aerial/Scissor Lifts)

A Mobile Elevating Work Platform (MEWP) can be defined as any vehicle mounted device, vertical, telescoping or articulating, or both, that is used to position personnel. Scissor lifts are considered a mobile-railed platform that can be raised straight up and down. Regardless of the definition, UNH departments, including Facilities Operations, Athletics, Memorial Union Building, the College of Liberal Arts (COLA), Campus Recreation, and Housing utilize both types of MEWPs for a variety of purposes.

The UNH MEWP Safety Program has several key elements that define responsibilities for those operating groups on campus that utilize them, establishes specific training requirements, and outlines limitations when it comes to non-UNH personnel (such as contractors). One of the significant components of the program is restricting MEWP use to only those trained and qualified UNH operators. A second key component is the establishment of training requirements for operators. Training is divided into two categories, Qualified/Competent Person Training and Restricted Person Training. Those employees that receive operator training and have experience and qualifications to safely utilize MEWPs are considered Qualified/Competent users. This allows them to utilize MEWPs in an unrestricted manner on campus. Restricted Persons are those that

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have received operator training however lack any use experience. These employees can utilize

MEWPs however their use requires oversite by a Qualified/Competent user. By dividing it up into two categories it allows key departments to utilize their own Qualified/Competent users to not only train their own personnel, but to decide when a Restricted Employee can become a Qualified/Competent user. In 2021 OEHS conducted training for the Environmental and Civil Engineering department to allow lift usage by faculty and staff during research conducted in Gregg Hall.

6.4.7 Workplace Safety Inspections

OEHS conducts routine inspections of campus locations to evaluate for the presence of hazardous conditions and works with campus groups to develop corrective measures. Inspections are conducted to identify hazards and work with management to develop corrective actions and address observed unsafe behavior practices. By continually observing for both unsafe conditions and unsafe behaviors of employee’s, efforts can be made to remediate hazards and correct unsafe actions through targeted training.

6.4.8 Hearing Conservation

Exposure to elevated noise levels that exceed exposure thresholds can lead to a temporary or permanent threshold shift that can result in noise induced hearing loss. OSHA has established the Occupational Noise Standard, 29 CFR 1910.95, which requires employers to develop and implement a Hearing Conservation Program should it have employees that exceed the established action level of 85 decibels as averaged over the course of an 8-hour day. Since there are areas/jobs at UNH where noise levels can exceed not only the Action Level, but the permissible exposure limit (PEL) of 90 decibels, OEHS manages the campus Hearing Conservation Program. For those impacted employees the program requires they receive training on the components of the program, the OSHA Standard, effects of noise exposure, and the appropriate use of hearing protection. In addition, each employee included in the Hearing Conservation Program is required to participate in baseline and annual audiometric testing. This testing is coordinated through the UNH College of Health and Human Services and is conducted at Hewitt Hall while training is conducted by OEHS.

Currently Grounds and Events are participants in the Hearing Conservation Program. In 2021 OEHS initiated efforts to evaluate noise levels in the Olson Manufacturing Center and anticipates continuing this effort throughout 2022.

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6.4.9 Respiratory Protection

Use of respirators at UNHis governed by a comprehensive OSHA Standard, 29 CFR 1910.134 Respiratory Protection which outlines specific requirements that must be met prior to and during use. OEHS manages the campus Respiratory Protection Program to ensure employees are properly protected against potential airborne contaminants as well as UNH‘s compliance with the OSHA standard. A respirator acts as a barrier preventing hazardous airborne contaminants from entering the body through the respiratory system. Contaminants can be physical, chemical, or biological in nature. For a respirator to be effective, it must be used following strict guidelines and procedures to ensure proper selection, use, care, and maintenance. In addition, all wearers of respiratory protection are required to participate in the UNH Medical Surveillance program and be fit tested annually. The fit test is the procedure where the employee dons the respirator they would be required to use and is challenged with a known agent. Should the employee detect the challenge agent, the respirator is not approved for use. Only those respirators that achieve an acceptable fit will be worn by employees. OEHS conducts training for a variety of departments that are covered by the respiratory protection program. These include Facilities Operations, Health and Wellness, and the NHVDL.

In 2021, the Respiratory Protection Program continued to expand to address the COVID- 19 pandemic which included coordinating medical surveillance, conducting training, and fit testing for a multitude of operational groups. Groups which needed expanded services included the COVID Testing Laboratories (Durham and UNH Manchester), College of Health and Human Services, Athletics, the College of Liberal Arts (COLA), and the UNH Police Department. In 2021 an additional 202 personnel participated in the medical surveillance program with 378 UNH Personnel receiving fit tests for respirator use.

6.4.10 Hazard Communication

The use of hazardous chemicals in the workplace is highly regulated to ensure those working with chemical substances do so in a safe manner. Using hazardous chemicals can place UNH employees and students at risk of exposures that can lead to physical injuries and/or illnesses. One of the programs developed and managed by OEHS is the Hazard Communication Program. This program is mandated by the OSHA Hazard Communication Standard, 29 CFR 1910.1200 and the State of New Hampshire Department of Labor Right to Know Law, Title XXIII, Chapter 277-A, Toxic and Hazardous Substances.

The Hazard Communication Program is designed to provide information to those who use or those who could be potentially exposed to chemical substances. The UNH Hazard Communication Program prescribes procedures for appropriate labeling of chemical containers, maintaining a comprehensive inventory of chemical materials at UNH, and ensuring that corresponding Safety Data Sheets (SDSs) are readily available for inventoried materials. In addition, training is provided on the provisions of the UNH Hazard Communication Program for

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all employees working with regulated chemicals. Hazard communication training was completed by 392 individuals in 2021. Facilities Division employees receive Hazard Communication training during their OEHS Orientation while others receive it while participating in laboratory safety programs.

UNH manages its chemical inventory and maintains over 65,000 SDSs electronically in UNHCEMS®. OEHS conducts an annual chemical inventory and is continually updating its compilation of SDSs to ensure the most up to date and accurate information is available.

6.4.11 Hot Work/Welding Safety

OEHS continues its advisory and administrative role for the Hot Work Permit Program. This program is designed to require those personnel who are required to perform welding, torch cutting, or any other heat and spark producing activities outside a designated hot work area to complete a Hot Work Permit (Figure 10). The program offers two options for hot work:

Option 1 - Those conducting hot work can opt to complete a single shift permit, which authorizes hot work for the single date specified on the permit. Completed by the UNH Facilities Project Manager and/or the Competent Hot Work Supervisor, the permit is forwarded to OEHS prior to the commencement of activities.

Option 2 - The second option available is to request a blanket permit. A blanket permit can be submitted to OEHS and will be reviewed on site with the appropriate UNH and/or contractor personnel. Once reviewed, the blanket permit is signed and approved. The blanket permit can be used for a time not to exceed 14 calendar days.

In 2021, OEHS received ninety-one (91) single shift hot work permits and reviewed two (2) blanket permit requests that were subsequently approved.

Figure 10: Sample Confined Space and Hot Work Permit Request forms

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6.4.12 Construction Safety

OEHS provides technical guidance to UNH project managers on environmental health and safety concerns during construction, demolition, and renovation projects. Services include minor technical inquiries, pre-construction plan review, and pre-demolition hazardous building materials abatement planning. In 2021, staff from all disciplines in OEHS participated in projects associated with Spaulding Hall; Transportation Building; Telecommunications; Dimond Library; Rudman Hall; Health Sciences Simulation Center; Kendall Hall; Barton Hall; Field House; McGregor Ambulance Building; University of New Hampshire at Manchester (UNH-M); and exterior locations involving utility upgrades throughout campus.

6.4.13 Occupational Safety Committee

The UNH Occupational Safety Committee assists with setting forth health and safety policies and programs that are adopted and implemented within the affected departments. The Occupational Safety Committee is a joint labor-management committee and is a vehicle through which the campus community can discuss safety concerns, disseminate information about programs and services from OEHS, and develop initiatives for future health and safety efforts. The Occupational Safety Committee incorporates representation from, Research Integrity Services, Housing, Campus Recreation, Athletics, Information Technology, Hospitality Services, Health & Wellness, Human Resources, Campus Stewardship; University Libraries, and the UNH Police Department (PD). OEHS coordinates and schedules the quarterly meetings, develops meeting agendas, and records and generates meeting minutes.

6.5 Safety Training and Education

Safety training is routinely performed and/or coordinated for those affected faculty, staff, and students on a variety of topics that include Hazard Communication, PPE, Respiratory Protection, Hearing Conservation, Control of Hazardous Energy (Lockout/Tagout), Confined Space Entry, Fall Protection, Asbestos Awareness, Material Handling, and Ergonomics. The responsibility for ensuring that affected staff receive the appropriate training falls under each individual department. OEHS offers training services that are pre-arranged with the affected departments.

Throughout 2021, OEHS continued its efforts to promote training to targeted areas where increased losses were occurring and to ensure compliance with regulatory training requirements. As part of their annual Associates Day, OEHS continued its partnership with Dining Services to address hazards and their controls associated with slips, trips, and falls, ergonomics/back/lifting safety, and cuts and burns. OEHS continued to provide training for the UNH Facilities Division by targeting specific areas that affect their operations that included the two-hour asbestos awareness training and the Facilities OEHS Orientation. In 2021 OEHS implemented the OEHS Housing Orientation designed to target those areas of risk for both full and part time Housing staff members. OEHS continued its partnership with Housekeeping to provide them with the annual asbestos awareness training.

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In 2021 3,424 employees and/or students participated in various instructor led and on-line OEHS training. Training was conducted on a variety of OEHS topics that include, but are not limited to Fall Protection, Confined Space Entry, Lockout/Tagout, Respiratory Protection, Bloodborne Pathogens, Radiation Safety, Laboratory Safety, and Oil Spill Response.

6.6 Ergonomics Programs

OEHS promotes its proactive approach to ergonomics by providing guidance to the campus community on ergonomic-related risks to reduce the number of claims involving musculoskeletal disorders associated with poor workstation design and manual material handling.

OEHS conducted twenty-eight (28) workstation evaluations in 2021. Each evaluation consists of the following:

• Reviewing the employee’s workstation.

• Discussing work processes and symptoms they may be experiencing.

• Adjusting and/or modifying the workstation; and

• Discussing with them proper body positioning.

In 2021 OEHS continued with assisting individuals virtually to address concerns related to working remotely. Virtual assessments can be conducted utilizing photo’s, Zoom, and/or facetime.

Each assessment is followed up by a formal report that not only summarizes our observations and modifications but includes additional recommendations to further reduce ergonomic risk factors. Simple modifications may include adjusting the employee’s chair height, repositioning the keyboard to an existing adjustable tray, or raising the monitor utilizing materials readily at hand such as books or reams of paper. More complex recommendations may include replacement of existing keyboards and mouse options, re-design of work processes to reduce repetitive motions or replacement of desks and chairs. Table 3 and Figure 11 summarizes the ergonomic losses dating back ten years. UNH experienced three (3) injuries associated with computer workstations in 2021 resulting in approximately $33,000 in losses. In addition, UNH experienced seventeen (17) injuries associated with manual handling and lifting resulting in approximately $102,000 in losses.

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Table 3 Losses (Claims) and Incurred Costs as a result of Ergonomic- Related Injuries at UNH

Year

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

Claims

10

3

1

3

2

5

9

18

19

20

Incurred Costs

$27,555

$4,892

$384

$15,603

$10,775

$3,994

$42,000

$61,800

$29,573

$135,000

Figure 11: Ergonomic Claims from 2007 through 2021 compared with Accrued monetary losses over time

OEHS continued to field many employee requests for information on sit-to-stand workstations (Figure 12), their purchase, and installation. This ergonomic trend has been shown to increase employee productivity and overall wellness. During 2021 sit to stand desk standards were incorporated into the UNH Planning, Design, and Construction Guidelines.

1517

22

15

810

31

32

5

9

1719

20

0

20000

40000

60000

80000

100000

120000

140000

160000

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 20210

5

10

15

20

25

Dolla

rs

Axis Title

Num

ber o

f Cla

ims

Ergonomic Claims versus Accrued Losses

Ergonomic Claims Ergonomic Accrued Losses

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2021 numbers Animal Handler-217 Respiratory Prot-567 Hearing-17 BBP-53 Asb-0

Figure 12: Example of a type of Sit-to-Stand workstation at UNH

6.7 Occupational Health Medicine

OEHS provides guidance to affected departments on medical surveillance requirements for faculty, staff, and students as required by state or federal regulations or as indicated by best management practices. Medical surveillance programs are established for respiratory protection, hearing conservation, asbestos, bloodborne pathogens and animal handlers. The management of the Animal Handlers Medical Surveillance Program and participant follow up is now under the responsibility of Research Integrity Services.

There are currently 816 faculty, staff, students and visitors participating in medical surveillance programs at UNH. As displayed in Figure 13, the number of staff enrolled in medical surveillance programs has increased when compared to 2020. In 2021, COVID-19 resulted in the need to enroll 202 additional employees into the respiratory protection program.

Figure 13: Number enrolled in Medical Surveillance programs from 2015 through 2021

330

78

26 17 1

361

5722 12 0

341

94

27 230

314

5219 13 2

194

78

20 13 2

156

406

22 15 0

217

567

1753

00

100

200

300

400

500

600

Animal Handler Respiratory Protection Hearing Conservation Bloodborne Pathogen Asbestos

Number Enrolled in Medical Surveillance Programs

2015 2016 2017 2018 2019 2020 2021

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6.8 Emergency Procedures

6.8.1 Emergency Procedures Program

It is the policy of UNH to maintain a safe environment for its students, academic appointees, staff, and visitors, in an atmosphere that encourages those individuals to communicate on occupational and environmental health and safety matters without fear of reprisal. The UNH Emergency Procedures Program (EPP) is required by OSHA and outlines procedures to be followed by the campus community for responding to, and recovering from, a variety of emergency and disaster situations. The purpose of the EPP is to facilitate and organize employer and employee actions during workplace emergencies. A well-developed emergency plan and proper employee training (such that employees understand their roles and responsibilities within the plan) should result in fewer and less severe employee injuries and less structural damage to campus facilities during emergencies. These events may include fires, hazardous spills, earthquakes, bomb threats, or major accidents.

Since 2016, the UNH Police Department has been the responsible for Emergency Management,

including the EPP..

7.0 Diving Safety Scientific diving is defined by OSHA regulations as diving performed solely as a necessary part

of a scientific, research, or educational activity by employees whose sole purpose for diving is to

perform scientific research tasks. UNH is exempt from the regulations that govern commercial

diving activities provided its program is defined as scientific diving and which is under the direction

and control of a diving safety program containing at least the following elements:

A diving safety manual that includes at a minimum: Procedures covering all diving operations

specific to the program; procedures for emergency care, re-compression and evacuation; the

criteria for diver training and certification; and a diving safety officer.

The Diving Control Safety Board (with the majority of its members being active scientific divers)

which shall, at a minimum, have the authority to: approve and monitor diving projects; review and

revise the diving safety manual; assure compliance with the manual; certify the depths to which

a diver has been trained; take disciplinary action for unsafe practices; and assure adherence to

the buddy system (a diver is accompanied by and is in continuous contact with another diver in

the water) for Self-Contained Underwater Breathing Apparatus (SCUBA) diving. UNH has

implemented both of these elements and is in compliance with this exemption.

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The following are statistics with regard to the Diving Program at UNH:

• Number of Divers logging dives during 2021: 34

• Total Number of Dives logged during 2021: 697

• Total minutes of diving logged during 2021: 23062

Tables 4 through Table 9 summarizes various dive statistics, including purpose for dives, modes

of diving, breathing gas types used, and equipment.

Table 4 Number of Dives distributed by Purpose in 2021

Purpose Dive Time in Minutes

Dives Logged Number of Divers Logging Dives

Scientific 14,496 404 30

Training and Proficiency 8,566 293 21

Shoal’s Marine Lab Dives No dives due to COVID precautions

Table 5 Number of Dives by Diving Mode in 2021

Diving Mode Dive Time in Minutes


Open Circuit SCUBA 23,062 697 34

Hookah 0 0 0

Surface Supplied 0 0 0

Rebreather 0 0 0

Table 6 Number of Dives by Breathing gas in 2021

Type of Breathing Gas

Dive Time in Minutes Dives Logged Number of Divers Logging Dives

Air 23,062 697 34

Nitrox 0 0 0

Mixed Gas 0 0 0

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Table 7 Number of Dives by Decompression Profiling Method in 2021

Decompression Method Dive Time in Minutes


Dive Tables 2,335 84 6

Dive Computer 20,727 613 34

PC-based Deco Software 0 0 0

Table 8 Number of Dives by Specialized Diving Environment in 2021

Diving Environment Dive Time in Minutes


Required Decompression 0 0 0

Overhead Environment 0 0 0

Blue Water 0 0 0

Ice/Polar 0 0 0

Saturation Diving 0 0 0

Aquarium Diving 0 0 0

Table 9 Number of Scientific or Training/Proficiency Dives by American Academy of Underwater Science

Dive Depth Dive Time in Minutes


0 - 30 feet 13,568 364 35

31 - 60 feet 8,571 303 32

61 - 100 feet 866 28 13

101 - 130 feet 57 2 2

131 - 150 feet 0 0 0

151 - 190 feet 0 0 0

190 - > feet 0 0 0

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There were no diving incidents reported in the 2021 cycle.

In addition to the scientific diving/AAUS listed above UNH runs several Academic open water

scuba classes each semester-the diving for that is as follows:

• Basic Open Water Scuba Classes for Spring(14 students) & Fall 2021(16 Students) for a

total of 30 Basic Students with approximately 20 hours of training in the pool for each

student leading to 4-5 open ocean dives each. Additionally, approximately 150 ocean

Student dives were conducted.

8.0 Disaster and Emergency Preparedness

OEHS reviews and updates Disaster and Emergency Response plans required by the United States Environmental Protection Agency (US EPA) for the Campus. OEHS is responsible for maintaining the Integrated Contingency Plan (ICP), Spill Prevention Control and Countermeasure Plans (SPCC) (40 CFR Part 112) and reporting to US EPA for Emergency Planning and Community Right to Know Act (EPCRA) Superfund Amendments and Reauthorization Act Title III (SARA Title III).

OEHS at UNH manages spill prevention plans for the following facilities:

• UNH Durham – Integrated Contingency Plan

• Combined Heat Plant, Durham Campus – SPCC

• Rochester Natural Gas Facility – SPCC

• Durham Water Treatment Plant - SPCC

OEHS at UNH files and manages EPCRA Tier II reporting for the following facilities:

• UNH Durham

• Shoals Marine Laboratory – Appledore Island Maine

• Rochester Natural Gas Facility- Rochester NH

• Goss Manufacturing Building – Durham NH

• C&C Dimes/EnviroVantage Warehouse – Northwood NH

Reporting and plan maintenance for each is described in greater detail in the following sections. 8.1 Integrated Contingency Plan

The US EPA National Response Team passed guidance in 1996 allowing facilities to prepare an emergency response plan (the ‘one plan’) that consolidates the multitude of response plans required by several federal agencies including: the US EPA; OSHA; the Department of Transportation (DOT); the Mineral Management Service; the United States Coast Guard; and the

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Research and Special Programs Administration.

UNH originally drafted the ICP for the Durham campus in 2009 and continues necessary revisions to the campus ICP as needed or, at a minimum an internal review is conducted on an annual basis. The current plan is dated and stamped by a licensed Professional Engineer (PE) and was last formally updated in June 2019. This plan requires a formal review and update be approved by a licensed PE every 5 years, or earlier if conditions change at the Facility that will materially affect the plan. In June 2019, an Amendment to the ICP was submitted by a PE due to the addition of portable emergency generators to the University’s storage tanks. OEHS anticipates the next formal update of the UNH ICP will be in June 2022 due to changes in oil storage that materially affect the plan.

The intent of the UNH ICP is to establish the necessary procedures and equipment required to prevent and to minimize hazards to public health, safety, or welfare, or to the environment, from fires, explosions, spills or any other unplanned sudden or non-sudden release of hazardous materials to air, soil, surface water, or groundwater. The plan is also designed to prevent spills or releases of hazardous substances that violate applicable water quality standards, cause a sheen upon or discoloration of the surface waters, or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

This plan contains three main sections: General Information, Spill/Release Response Procedures, and Spill/Release Prevention.

• Section I – General Information describes UNH’s facilities and the administration of this plan, including procedures for the distribution, periodic review, and amendment of the plan.

• Section II –Fire, Explosion, or Spill/Release Emergency Response Procedures identifies and establishes the response and notification procedures to be used in the event of a spill/release, including steps to be taken when a spill/release is discovered; how to report a spill/release; guidance on mitigation and cleanup of a spill/release and disposal of related waste; and a description of spill/release response equipment maintained by UNH.

• Section III - Fire, Explosion, or Spill/Release Prevention identifies and establishes policies and procedures to be implemented with the goal of reducing the potential of a spill/release, including: a detailed description of areas of the facility where oil, petroleum products and hazardous materials and wastes are used, stored and generated; the associated containment systems; a description of the potential environmental receptors that may be affected; procedures for inspecting storage areas or equipment containing oil or hazardous waste; delivery/storage procedures; and a discussion and assessment of the potential spill/release scenarios.

The areas of the University of New Hampshire property that are covered by the ICP include:

• Durham campus;

• UNH Central Hazardous Waste Accumulation Area (CHWAA);

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• Satellite Accumulation Areas in laboratories and research facilities throughout campus;

• UNH Facilities including the Heating Plant and shops;

• Transportation Garage;

• All other perimeter farms in Durham with the contiguous property boundaries of UNH Durham campus;

• Residential housing for college students and employees (single-family residences are exempt when oil is used exclusively for on premise heating); commercial properties owned or partially owned by the UNH, and situated contiguous to the main campus in Durham; and

• Other miscellaneous properties owned by the University of New Hampshire, with property boundaries contiguous to the Durham campus.

Due to their limited onsite storage of regulated materials, the Shoals Marine Laboratory (Appledore Island, Maine), Coastal Marine Laboratory (New Castle, New Hampshire), Burley- Demeritt Farm (Lee, New Hampshire), Kingman Farm (Madbury, New Hampshire) and UNH-M do not have formal SPCC or ICP plans. Although law does not require formal plans for fuel or hazardous materials spill responses at these locations, OEHS continues to monitor petroleum and hazardous materials storage and manages them as a best practice in accordance with US EPA and NHDES regulations.

OEHS provides oversight and training relative to spill prevention control and counter measures plans developed for the UNH Durham Campus Central Heating Plant, the Durham-UNH Water Treatment Plant, and the Landfill Gas Processing Facility in Rochester New Hampshire.

The SPCC plan for the Central Heating Plant was last certified in December 2019. The SPCC plan for the Water Treatment Plant certified in June 2020. The Landfill Gas Processing Facility in Rochester New Hampshire has an SPCC plan last certified in August 2019.

8.2 Spill Prevention Control and Countermeasure (SPCC) Planning

The priority of the US EPA Emergency Management Program is to prevent, prepare for, and respond to oil spills that occur in and around inland waters of the United States. US EPA is the lead federal response agency for oil spills occurring in inland waters, and the United States Coast Guard is the lead response agency for spills in coastal waters and deep-water ports. The SPCC rule provides requirements for oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule (40 CFR Part 112) requires facilities that meet specific petroleum storage quantities to prepare, amend, and implement SPCC Plans.

UNH maintains certified SPCC plans for the Combined Heat and Power Plant, the Town of Durham Water Treatment Plant, and the UNH Landfill Gas Processing Facility in Rochester. The plans for the Durham Water Treatments Plant was last updated in YY2021; the UNH Landfill Gas Processing Facility and the Combined Heat and Power Plant were both reviewed by a licensed

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Professional Engineer and revised in 2019.

In place of an SPCC for the Durham Campus, an ICP has been developed and maintained for UNH as discussed in section 8.1 above. The completion of the certified ICP meets the US EPA requirement for a spill prevention plan (40 CFR Part 112)

UNH Facilities staff conducts monthly inspections of the 55 aboveground oil storage tanks (ASTs) on campus and 8 registered transformers, with an additional 104 transformer inspections occurring annually, as conducted by the UNH Energy office. There are several factors determining which equipment is inspected and at what frequency and is in part defined by the facility ICP, SPCC and or NHDES regulations.

Per US EPA SPCC regulations (as detailed in the ICP), OEHS conducted in-person training for 86 UNH staff and contractors have received an awareness level for prevention of oil discharges and reporting and response procedures. Nine UNH personnel are identified as oil handling personnel and receive training for the operation and maintenance of equipment to prevent oil discharges; discharge procedure protocols; applicable pollution control laws, rules and regulations; general facility operations; and the contents of the various facility ICP and SPCC Plans.

OEHS continues to monitor total oil storage at Shoals Marine Laboratory. Since oil storage reduction of 2015, Shoals Marine Laboratory staff continue to reduce and minimize oil use and storage at the facility. This continued approach of overall reductions in oil storage and use on the Island means a SPCC plan is no longer required for the Shoals Marine Laboratory, as it does not meet the de-minimis threshold planning quantity of 1,320-gallons of above ground petroleum storage, in aggregate containers of greater than 55-gallons each. Current petroleum storage on the Island is now 1,256-gallons. To maintain best practices, OEHS will maintain oil spill response procedures in the Hazardous Materials Emergency Management Plan for Shoals Marine Laboratory and provide annual training to the Shoals Marine Laboratory staff for oil spill prevention and response.

8.3 Emergency Planning and Community Right-to-Know

EPCRA, also known as SARA Title III, is a statute designed to improve community access to information about chemical hazards and to facilitate the development of chemical emergency response plans by State and local government. EPCRA requires the establishment of State Emergency Response Committees (SERCs) responsible for coordinating certain emergency response activities and for appointing Local Emergency Planning Committees (LEPCs). The emergency planning requirements of EPCRA are designed to develop state and local government emergency response and preparedness capabilities through better coordination and planning, especially within the local community. The submitted reports are known as Tier II reports and are submitted March 1st annually. The Environmental Compliance Manager within OEHS attends briefings annually held States of New Hampshire and Maine along with the USEPA Region 1 representatives to learn about changes and guidelines for reporting.

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UNH maintains threshold planning quantities of extremely hazardous substances and chemicals in quantities greater than 10,000 pounds at the UNH Durham campus, the Shoal’s Marine Laboratory on Appledore Island, Maine, and the Landfill Gas Processing Facility in Rochester New Hampshire. OEHS completed and submitted Tier II Reports for facilities to regulatory agencies in 2020.

At the Shoal’s Marine Laboratory, for reporting year 2021, OEHS identified sulfuric acid and lead

found in batteries utilized in equipment and the solar panel array that required Tier II reporting

under this EPCRA program. There were no changes in reporting or quantities from 2020 to 2021

for Shoal’s Marine Laboratory.

For reporting year 2021 (submitted in March 2022), OEHS notified the SERC and the LEPC that

UNH stores 17 materials, chemicals, and or mixtures that fall above the threshold planning

quantity that are required reporting to local and state government. Table 10 below summarizes

the Tier II Reporting for the UNH Durham campus from 2017 through 2021. The staggering

decrease in quantities of sulfuric acid from 2018 on, is a result of the interpretation of the

regulation to not include consumer-use batteries in reporting. The amounts reported in previous

years was conservative and included batteries used in standard fleet vehicles across campus

Table 10 EPCRA Tier II Chemicals reported for UNH Durham Campus for Reporting Years 2017 through 2021

Chemical RY2017 RY2018 RY2019 RY2020 RY2021 Ammonia 2,050 3,398 2,034 2,044 2,039 Chloroform 941 1,038 1,047 973 994 Diesel 25,915 25,915 29,596 35,013 35,013 Formaldehyde NR 751 436 350** 326 FR3 (transformer fluid) 77,368 108,416 113,125 138,600 138,600 Fuel Oil #2 522,672 590,805 521,944 521,944 521,944 Hydraulic Oil (elevators) 87,336 88,006 88,006 88,006 88,006 Mineral Oil (transformers) 111,600 104,710 88,016 64,284 64,284 PCH-180 (Inorganic Aluminum Salt)

63,088 52,542 52,542 52,542 60,528

Propane 113,867 112,971 112,856 104,011 104,030 R-TEMP (transformer fluid) 54,455 44,664 38,440 42,741 42,741 Sand 100,000 100,000 100,000 100,000 100,000 Salt 607,350 607,350 607,350 607,350 607,350

Sodium Hydroxide 59,195 61,093 166,051 130,683 104,788 Sodium Hypochlorite 24,315 30,808 25,739 25,195 11,133 Sulfuric Acid 2,141 2,853 2,347 2,393 2,293 Sulfuric Acid (Batteries)* 19,420 820 820 820 820 NR Not Reported, did not meet threshold planning criteria All quantities reported in pounds

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Additionally, the UNH EH&SO completed and submitted Tier II report to the Town of Northwood New Hampshire. The filing of Tier II report for this location is a result of isopropyl alcohol and ethanol in hand sanitizer above the reporting threshold. UNH Emergency Management received and is storing roughly 325,000 pounds of hand sanitizer as part of the COVID pandemic response efforts. Officials in the Emergency Management Office will continue to distribute hand sanitizer but does not plan to receive additional quantities until stockpiles are depleted. UNH OEHS is currently assisting Emergency Management with finding ways to successfully recycle or dispose of the excess quantities of materials stored at the EnviroVantage Warehouse in Northwood New Hampshire.

9.0 Environmental Monitoring

9.1 Air Quality

9.1.1 Title V Air Permit

The NHDES renewed UNH’s Title V Air Permit (TV-OP-010) for the campus Central Heating Plant and Co-generation Facility on March 16, 2018. The renewed Title V Air Permit also incorporated the requirements of Temporary Permit and Prevention of Significant Deterioration and Non- Attainment New Source Review permit (TP-B-0531) for the construction and operation of combustion devices associated with the Landfill Gas to Energy facility at Rochester and on the Durham campus, as well as the requirements of Temporary Permit (TP-0161) for the replacement of one of the Central Heating Plant boilers.

The NHDES issued Temporary Permit (TP-0215) for the construction of a biomass boiler system at The Thompson School of Applied Science on March 20, 2018. UNH submitted a request to NHDES on July 29, 2019 for a minor modification to its Title V Operating Permit TV-0010 to include all of the permit terms and conditions related to the Thompson School District Biomass Boiler System (EU26) from Temporary Permit TP-0215. On January 7, 2020, NHDES issued a minor modification to UNH’s Title V Operating Permit TV-0010 to include all permit terms and conditions from UNH’s Temporary Permit TP-0215.

UNH’s current Title V and Temporary permits contain specific conditions that the campus must adhere to, including an annual compliance certification report. UNH filed all periodic reports on a timely basis in 2021.

9.1.2 Air Toxics

An Air Toxics Control Program for the State of New Hampshire was established in 1987 to help protect the health of New Hampshire residents and preserve the environment. This program, together with the US EPA program to control hazardous air pollutant emissions as set forth in Section 112 of the 1990 Clean Air Act Amendments (CAAAs), is designed to reduce the emissions and ambient air impacts of a number of toxic air pollutants likely to be emitted by businesses and industry in the state. Title III of the CAAAs identified 188 hazardous air pollutants (HAPs) that are

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likely to have the greatest impact on ambient air quality and human health on a national level. The list of HAPs regulated by EPA is published in Section 112 of the CAAAs.

The NHDES Air Toxics Control Program regulates HAP emissions, as well as over 800 regulated toxic air pollutants (RTAPs), which have a health-based risk to humans. The aim of the regulatory program is to protect public health and the environment by establishing ambient air limits (AALs) and requiring businesses in the state to reduce their emissions of any of the RTAPs, such that they do not impact the downwind air quality at levels that may exceed the established AALs. The list of RTAPs, published in NH Code of Administrative Rules Chapter Env-A 1400 Regulated Toxic Air Pollutants includes: (1) those compounds listed as HAPs by US EPA; (2) those chemical substances for which a threshold limit value has been established by the American Conference of Governmental Industrial Hygienists (ACGIH); and (3) those compounds not otherwise included that are regulated by OSHA. The AALs are reviewed and updated every year as new scientific data on toxicity becomes available.

In July 2020, OEHS updated the University of New Hampshire’s air toxics compliance demonstration required under New Hampshire Air Regulation, Chapter Env-A 1400 that was initially prepared in December 2000 and subsequently updated in September 2003, March 2007, February 2009, October 2010, March 2011, April 2013, July 2013, January 2015, February 2016, March 2017, June 2017, March 2018, and July 2019. UNH’s compliance demonstration is for the Durham campus, Manchester campus, Law School (Concord) and the Landfill Gas Processing Facility located in Rochester. As part of this updated compliance demonstration, the following activities were carried out:

• Updated UNH Printing Services products and actual usage rates for calendar year 2019 and reviewed safety data sheets (SDS) to identify any new Regulated Toxic Air Pollutants (RTAPs) not covered by the previous update and to assess changes in usage rates.

• Reviewed and updated emissions from the combustion of Landfill Gas (LFG) at the Landfill Gas to Energy (LGTE) facility.

• Reviewed and updated compliance demonstration for cooling tower RTAP emissions.

• Reviewed SDS and determined compliance for degreasing materials used at the Heating Plant and vehicle maintenance shop.

• Reviewed activities at the Paul Creative Arts Center (PCAC) and Morse Hall 145 paint booths.

• Reviewed existing activities identified in UNH’s previous compliance demonstration to identify any significant changes to operations and/or equipment.

Upon completion of the review, the results indicate that UNH is in compliance with the ambient air limits listed in Chapter 1400 based on uncontrolled emissions and that a permit for controlling RTAP emissions is not required.

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UNH will be updating its air toxics compliance demonstration following issuance of final updates to NHDES’s regulation, Chapter Env-A 1400. The regulation is anticipated to be finalized in late January or early February 2022 and UNH will have 90 days from publication to update its compliance demonstration.

9.1.3 Refrigerant Management Program

The purpose of UNH’s Refrigerant Management Program (RMP) is to:

• Maximize the recycling of ozone depleting substances (ODS) and to minimize the release

of ODS to the ambient air from the servicing, repairing, maintaining, and disposing of refrigeration appliances on its Durham, Manchester, and Concord campuses;

• Utilize certified technicians for the servicing, repairing, maintaining, and disposing of refrigeration appliances on its Durham, Manchester, and Concord campuses;

• Maintain proper records of refrigerant consumption, technician training, and recycling and recovery equipment certification;

• Ensure proper repairs are made for units with significant leak rates; and

• Ensure UNH is in full compliance with Section 608 of the Clean Air Act (CAA) and the requirements of 40 CFR Part 82, Subpart F.

To achieve the stated objectives above, UNH requires all employees and contractors whose job duties require the handling, ordering, repairing, servicing, maintaining, or disposing of refrigerant or refrigeration appliances to review and comply with this written program.

An RMP stakeholder meeting was last held in June 2019, and a subsequent meeting and full RMP update is planned for 2022. UNH has also updated its records management software which should further improve compliance documentation related to Subpart F.

9.2 Impacted Soils Management – Urban Fill

OEHS continued support of Facilities and Planning Division with management of Urban fill and

soils impacted with hazards materials on campus in 2021.

As discussed in the 2019 Annual report, Urban Fill has been noted in a number of areas across

campus. Urban fill commonly consists of granular native soil or fill that contains combustion

derived materials such as coal ash, wood ash, slag, and/or cinders, along with anthropogenic

materials that may include brick or concrete. Urban fill encountered on campus is likely associated

with the former incinerator that was housed on campus where the current heating plant exists.

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Initial soil sample analytical results of the urban fill indicated the subsurface material contained

low levels of polycyclic aromatic hydrocarbons (PAH’s) among other combustion by-products at

varying concentrations. In 2018, OEHS developed a Soil Management Plan - Urban Fill Soil (Soil

Management Plan) and a Health & Safety Plan (HASP) specific for working in areas where Urban

Fill is encountered to address the recommendations for self-management by the NHDES.

The Soil Management Plan includes measures for proper stockpiling of site soils with onsite

management (bury with cap) or offsite disposal, management of workers and implementation of

engineering controls to minimize migration of material and the protection of the community from

contact with soils during construction and after the projects are completed.

In addition, the Soil Management Plan includes information on how to visually identify Urban Fill,

provides information on the chemical constituents found in Urban Fill on campus, proper

management techniques and site controls to minimize migration of soil and dust, as well as proper

procedures when burying the soil on-site. The Urban Fill HASP addresses proper procedures for

engineering site controls and personnel protective equipment and procedures to protect human

health.

UNH OEHS teamed up with the UNH Planning Geographic Information Systems group to map (in

UCAT) areas on campus known or suspected to have potentially recognized environmental

conditions. Having this information mapped on UCAT provides Facilities Project Managers and

Planners with one more tool to help manage and realize potential impacts to construction and

utilities projects. A new area has been mapped in UCAT as a potentially recognized environmental

condition in 2021. Higher levels of arsenic were found in native soils in the areas of the UNH

Durham campus below ground level surrounding the Transportation Garage. The elevated levels

of arsenic were discovered during routine excavation end point sampling following the removal of

a hydraulic lift system. The New Hampshire Department of Environmental Services agreed the

levels are naturally occurring in the area and not a result of human activities at the site (historic

or present included). Although the arsenic is naturally occurring in overburden soils, the presence

in soils in this area represents a potentially recognized environmental condition.

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10.0 Laboratory Safety

10.1 Biological Safety

10.1.1 Institutional Biosafety Committee Use of Cayuse Hazard Safety Software

OEHS implemented the Cayuse Hazard Safety software for Institutional Biosafety Committee

use in January 2021. The new software gave Principal Investigators were given the opportunity

to register their work using the new system. Once the Hazard Safety module is on the platform

with the other Cayuse modules used by SPA, the full benefit of using a single system and

dashboard from award through compliance will be realized.

10.1.2 Institutional Biosafety Committee

The Institutional Biosafety Committee consists of thirteen members representing each of the campuses whose work includes recombinant or synthetic nucleic acids and biohazardous materials. In 2021, the Committee went from eleven members to thirteen, adding representation from the Chemistry and Biomedical Engineering departments. The meeting schedule was expanded from quarterly meetings to every other month based on the increase in the number of protocols for review and the challenges with the Cayuse review process.

Table 11: 2021 IBC Membership

Name Representing Affiliation

Dana Buckley Environmental Health and Safety UNH

Audrey Cline Municipal: Durham Code Enforcement Community

John Collins Molecular, Cellular, and Biomedical Sciences UNH

Sherine Elsawa Molecular, Cellular, and Biomedical Sciences UNH

Andy Glode Environmental Health and Safety UNH

Karen Jensen Sponsored Programs Administration UNH

Stephen Jones Natural Resources and the Environment/Jackson Lab UNH

Linqing Li Chemical Engineering UNH

Carol Loring Private Industry Community

Kyle MacLea (CHAIR) UNH Manchester Life Sciences UNH

Subhash Minocha Biological Sciences UNH

Linnea Morley Animal Resource Office UNH

Nathan Oldenhuis Chemistry UNH

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The IBC reviewed and approved 28 protocols and 14 amendments in 2021. There are 76 active protocols across four colleges being overseen by the Committee. The protocols represent research and teaching projects in Biosafety Level 1 (BSL-1) and Biosafety Level 2 (BSL-2) containment (Figure 14, below).

Figure 14: Research and teaching projects in Biosafety Level 1 and Biosafety Level 2 containment

The annual report for the Institutional Biosafety Committee was submitted to the National Institutes of Health on April 30, 2021, and was accepted on June 1, 2021. Laboratory inspections were completed in support of newly registered protocols; however, as in 2020, due to COVID pandemic protocols, in 2021 inspections for renewal protocols were put on hold in some instances.

Durham and Manchester campuses have a total of one hundred sixty-seven (167) biolabs; seventy-nine (79) are BSL-2 containment labs and sixty-one (61) are BSL-1 containment labs. The Animal Resource Office operates fourteen (14) Animal Biosafety Level 1 (ABSL-1) labs and two (2) Animal Biosafety Level 2 lab. Eleven (11) rooms have miscellaneous BSL-2 activities such as biowaste processing and blood draws. Figure 15 summarizes the biosafety laboratory types across campus.

32%

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Biosafety Level 1 Biosafety Level 2

64%

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Research Teaching

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Figure 15: Biosafety lab type distribution

10.1.3 Engineering Controls

Biological Safety Cabinets (BSC) are the primary engineering control for containment of infectious aerosols when handling biohazardous materials. Durham and Manchester campuses have Class IIA2 recirculating cabinets, which are appropriate for the research and teaching labs handling biohazardous materials. The campuses operate a total of eighty-eight (88) cabinets for biohazardous work. In 2021, biological safety cabinets were added to the Biotechnology Innovation Center in Manchester and for the second COVID testing lab set up in Gregg Hall. In addition to Biological Safety Cabinets, the Durham campus has three (3) bioBubble units which are engineering controls specially made for aerosol containment for large pieces of equipment and/or entire rooms. The COVID testing labs have one (1) each for equipment, and the Animal Resource Office has a room sized bioBubble set up for Animal Biosafety Level 2 work. Equipment is certified annually by the department that owns it and OEHS maintains certification data in UNHCEMS®.

10.1.4 Autoclave Treatment of Biohazardous Waste

Biohazardous waste is treated prior to disposal in areas that have access to a steam autoclave. In buildings where a steam autoclave is used for treatment, UNH must comply with the Department of Environmental Services regulation ENV-Sw-904, Infectious Waste. To ensure compliance, OEHS tests and maintains records for ten (10) pre-vacuum steam autoclaves in Rudman Hall, James Hall, Gregg Hall, and Jackson Estuarine Laboratory. None of UNH’s autoclaves require a permit from NH DES; however, to meet the regulatory requirements, a total of forty-seven (47) quality tests were performed in 2021.

14 2

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The NH Veterinary Diagnostic Lab also operates a validated autoclave for biological waste and maintains their own quality records.

Figure 16: Autoclaves for steam sterilization of biohazardous waste

10.1.5 Institutional Animal Care and Use Committee

Two representatives from OEHS work with the Institutional Animal Care and Use Committee (IACUC) for biological safety and occupational safety issues. The IACUC and Institutional Biosafety Committee overlap in the review of transgenic animal strains and biological vector use in animals. Coordination between both committees is essential for timely review and approval of scientific research.

10.1.6 Bloodborne Pathogens Program

The annual review of the campus Exposure Control Plan was completed in December 2021. There were nine (9) blood exposure or sharps injuries reported in 2021. Six (6) people completed the Safety Engineered Sharps Survey located on UNHCEMS® as part of the Bloodborne Pathogens program, and of the departments tracked by OEHS, fifty-three (53) employees completed the Hepatitis B declination form. Departments such as UNH Police, Athletics, Campus Recreation, Nursing, and Health and Wellness maintain their own training and vaccine records. OEHS maintains records in UNHCEMS® for departments that elect to take online training.

64%9%

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Rudman Hall

James Hall

Gregg Hall

Jackson Estuarine Laboratory

NHVDL

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10.1.7 Biosecurity

COLSA continues its biosecurity program for the second floor of Rudman Hall. Principal Investigators are responsible to keep an accurate record of their biological inventory, and OEHS provides technical support as needed for any PI requesting to keep their inventory in UNHCEMS®.

10.1.8 Training

Twenty-one (21) biosafety training modules were posted and offered through the online UNHCEMS® system in 2021. These modules represent training in Animal Biosafety Level 1, Animal Biosafety Level 2, Biosafety Level 1, Biosafety Level 2, Biosafety Awareness, Bloodborne Pathogens, Sharps Safety, Autoclaving Biohazardous Waste, IBC Member Training, and Principal Investigator Training. Participation in biosafety training by type is shown below in Figure 17.

Figure 17: Participation in biosafety training by type of requirement

10.2 Chemical and Laboratory Safety

10.2.1 Laboratory Safety Inspections

Formal, laboratory safety inspections were not performed due to the continued COVID-19 pandemic as well as staffing shortages within the Environmental Health & Safety Office. However, laboratory safety issues observed during visits, such as chemical inventory deliveries, the annual chemical inventory, and chemical fume hood inspections, are shared with PIs for follow up.

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Training Completed By Type

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10.2.2 Chemical Safety Committee

OEHS continues to administer and support the UNH Chemical Safety Committee (CSC). Representatives from OEHS organize and attend quarterly meetings, compile minutes, draft appointment letters, and fulfill other administrative requirements for the committee. This year, progress regarding COVID-19 mitigation efforts, testing, and other insights were shared. Additional discussions included topics such as the Chemical Hygiene Plan, the UNH Chemical Safety Award, the hazardous waste inspection, laboratory safety updates, laboratory safety renovations, laboratory ventilation, UNHCEMS updates.

10.2.3 Regulatory Compliance Services

OEHS continued to monitor and ensure institutional compliance with the US Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS). This regulation requires facilities that possess or transfer certain “Chemicals of Interest,” to file an in-depth screening report with DHS and comply with certain security requirements. The list of Chemicals of Interest includes over 300 chemicals that could potentially be used for sabotage or the creation

of a weapon of mass effect. OEHS uses UNHCEMS® to evaluate the campus inventory for Chemicals of Interest and works with owners to ensure the inventories are accurate.

OEHS administration of the UNHCEMS® Parsons Hall Flammable Liquid Report in 2021 resulted in successful maintenance of compliance obligations. UNHCEMS® automatically sends an alert to OEHS, Principal Investigators, and the DFD when volumes of flammable liquids in laboratories in Parsons Hall exceed fire code storage limits. In addition, UNHCEMS® sends a warning to OEHS and Principal Investigators (PIs) when inventories approach the storage limit, allowing us to evaluate inventories internally before reporting to the fire department is required. OEHS continues to work with PIs to facilitate accurate reporting of flammable liquid inventories and accurate reporting to our emergency responders. This year, three warning threshold alerts were initiated, resulting in PIs reviewing their inventories listed in UNHCEMS®, and correcting records as necessary. No over-limit alerts were initiated this year.

10.2.4 Chemical Fume Hood and Laboratory Ventilation Assessments

OEHS continued to perform detailed evaluations of laboratory chemical fume hood operation and performance in 2021 ensuring essential functions. OEHS assesses operation of each UNH’s 448 fume hoods annually and whenever hoods are reported to have operational deficiencies. This year, OEHS conducted 1339 fume hood assessments (Figure 18). The chemical fume hood is the primary engineering control protecting workers in research laboratories from hazardous chemical exposures; as a result, OEHS dedicates significant resources to evaluate fume hoods for safe operation.

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Figure 18: Fume Hood inspection and inspection types performed by OEHS

In 2021, OEHS continued to put significant emphasis on confirming safe operation of chemical fume hoods in teaching laboratories in Parsons Hall and Rudman Hall. Fume hood failures in teaching laboratories can have a significant impact on student safety and course schedule, so OEHS performs a minimum of twice annual assessments of hoods in teaching laboratories in the month before class begins. OEHS worked with the Facilities Maintenance staff to expedite repairs and help ensure classes were not disrupted.

OEHS performed building-wide assessments of fume hood performance following the completion of planned and unplanned shutdowns of building ventilation systems as outlined in the UNH Ventilation Management Plan. OEHS performed building-wide preventative maintenance assessments in Rudman, Spaulding, James, Gregg, Parsons, Demeritt, and Kingsbury.

In addition to evaluation of chemical fume hoods, OEHS also assesses operation of other laboratory ventilation components that may influence worker health and safety. These components include gas cabinets, snorkel exhausts, canopy exhausts, other point source ventilation, valve and actuator operations, dampers, and alarms and control devices including face velocity monitors and flow controllers.

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10.2.5 Laboratory Design and Renovation

OEHS provides technical input and support for laboratory design and renovation projects including during planning phase, construction, and commissioning. OEHS tested fume hood performance as well as other laboratory exhausts, evaluated face velocity monitor function, reviewed eyewash and deluge showers, flammable cabinets, chemical storage cabinets, safety equipment availability, egress, laboratory heating, ventilation and air conditioning (HVAC) function, and chemical storage. This year, OEHS provided input and support for the following projects:

• Continued to provide extensive input on project expanding and renovating Spaulding Life Sciences building.

• Installed upgraded electrical outlets to support a research laboratory in Rudman Hall.

• Participated in planning meetings and about Barton Hall renovation for LLMP, Soil Diagnostics, and Plant Diagnostics.

• Provided lab design expectations for a forensic analysis laboratory to include chemical and biosafety level 2 work.

• Participated in the Rudman Hall laboratory heating ventilation and air conditioning (HVAC) multi-year project to correct system deficiencies including providing input about project goals and scheduling including weekly project meeting, safety training for contractors, and commissioning testing for renovated fume hoods. Evaluated commissioning testing by outside contractors for conformance with UNH safety expectations.

10.2.6 Laboratory Safety Technical Services

OEHS staff provides technical safety services to teaching and research laboratories at UNH and UNH-M. These services include providing chemical safety information, incident investigation, odor investigations, laboratory exhaust evaluation, recommendations for chemical storage and segregation, assessment of PPE, reproductive health assessments, and regulatory compliance services. Examples of select projects and services performed in 2021 include the following:

• Convened group of technical experts to provide support designing a research environmental growth chamber for use with isotopically labeled carbon. Chemical and electrical safety were main considerations in design discussions.

• Assisted Parsons Hall occupants maintaining flammable liquids inventory below regulatory limits.

• Assisted teaching laboratory wit guidance for long-term storage of chemicals as laboratory courses are displaced during a building renovation.

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• Provided technical support for management of laboratory ventilation shutdowns in research and teaching facilities.

• Advised researcher on proper use of extension cords in laboratories and strategies to avoid safety and compliance issues.

• Worked with researcher group on development of written protocols and storage practices for 1-hydroxybenzotriazole hydrate.

• Summarized issue of failing chemical fume hood potentiometers at Parsons Hall.

• Collaborated with Olsen Center on fabrication of a bench-top spray booth for a mechanical engineering lab.

• Reviewed proposed CO2 monitor for a research laboratory and determined proposed product was not designed for safety purposes; identified a suitable replacement.

• Assisted with development of storage practices for a pyrophoric chemical in a chemistry research laboratory.

• Coordinated efforts to decommission hazardous gas use from a mass spec laboratory. CO, H2, SO2 were removed from the lab, significantly reducing institutional risk.

• Collaborated with the Energy office and an outside engineering firm to evaluate laboratory airflow in a research building.

• Provided support in evaluation of mercuric chloride use in a chemistry undergraduate teaching laboratory.

10.2.7 Laboratory Safety Training

OEHS provides laboratory safety training for the campus community. Below is a list of trainings provided and number of individuals who completed the training (Table 12).

Table 12 Laboratory Safety Training Provided in 2021

Training Title and Description

2021 attendees

Laboratory and Chemical Safety Training: fundamentals of chemical safety, hazard communication, controlling hazards, emergency response procedures.

223

Laboratory Safety Awareness for Introductory Level Laboratory Sciences 1882

Review of Laboratory and Chemical Safety: live review session for those who have already completed Laboratory and Chemical Safety Training

12

Cryogenic Liquid Safety Training: required for those using liquid cryogens 49

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11.0 Hazardous Materials

11.1 Chemical Transfer Station

OEHS continued to operate the Chemical Transfer Station (CTS) in 2021. Chemical orders for all research chemicals, except those for the Chemistry Department, are received at the CTS.

OEHS staff receive chemical deliveries at the CTS, barcode the chemical containers, and collect information required for the chemical inventory. Packages are then re-sealed and delivered directly to research laboratories on the same day the package is received.

Annual trends for 2021 (Figure 19) showed a continued increase in containers from 2020. The sum of containers added to the inventory in 2021 includes routine new containers, chemicals ordered by the COVID lab, chemical containers found in labs during inventory verification without barcodes, and approximately eight hundred (800) 2020 containers which were labeled with misprinted barcodes and were replaced with 2021 barcodes during the inventory verification.

Figure 19: Chemical containers received, processed and delivered by the OEHS Chemical Transfer Station per year

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Figure 20: Monthly breakdown of chemical containers processed by OEHS throughout 2021

11.2 Chemical Inventory Verification Program A chemical inventory audit was performed from May 17th through July 10th, 2021. This operation is essential in verifying the numbers of chemicals on site and ensuring UNH stays within permitted limits for occupancy agreements. During the course of 37 days, the inventory team scanned over 35,000 chemical containers in 390 laboratories across the UNH Manchester and UNH Durham campuses. An additional 1,744 containers were barcoded while in the field and approximately 800 containers marked empty.

11.3 UNHCEMS® Inventory

Data collection and compliance reporting for OEHS relies heavily on UNHCEMS®. Indeed, the entire University Community uses UNHCEMS®. Approximately 21,287 active users (as compared to 18,874 active users from 2020) accounting for faculty, staff, students, visiting researchers, and contractors, among others that have access to the UNHCEMS® software program online. The dramatic continued increase in users is directly related to UNHCEMS® as the resource for tracking COVID testing compliance through the Wildcat Pass.

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As mentioned in other sections of this Annual Report, UNHCEMS® is widely used by the University to track other programs such as training, radiological materials, laboratory equipment, and environmental programs. OEHS assists the UNH community with gaining access to resources provided by UNHCEMS®, including training and technical support and acting as a liaison between the software development team in research computing center and campus stakeholders.

Additional UNHCEMS® statistics for the calendar year of 2021, relative to the UNH Durham campus chemical inventory and hazard communications include:

• 46,078 active containers on campus

• 7,174 containers marked empty

• 68,112 SDSs in library

• 654 active Door Signs

OEHS continues to work with researchers and staff to reduce the amount of legacy chemicals across campus. UNHCEMS® is instrumental in identifying legacy chemicals and keeping track of laboratory moves. Data from UNHCEMS® is exported to the Laboratory Safety Manager for review once a researcher or faculty has retired or has been assigned new laboratory space to not only review the inventory for disposal but also to identify chemicals that may be valuable to other researchers and have them redistributed. All chemical waste disposal is tracked in UNHCEMS®

providing readily exportable datasets for the Hazardous Waste Manager in OEHS.

11.4 Hazardous Materials Shipping

OEHS continued efforts to maintain compliance with hazardous material shipping regulations by offering guidance, training, on-site review, and reference material to the UNH community. OEHS provided professional guidance and training to 19 UNH research groups in 2021. This included providing guidance for domestic and international research material shipments.

OEHS continued a partnership with the Thompson School Veterinary Technician Program to offer shipping certification training to students. As students enter their profession, they will likely have responsibilities to ship infectious and potentially infectious samples. Providing the necessary training to perform these tasks will help students market themselves to prospective employers. Twenty (20) students in the Veterinary Technician program attended this training which was offered as part of their coursework.

OEHS offers shipment of dry ice online training ice online. In 2021, eight (8) researchers passed the training requirements to receive a certificate ship dry ice by air.

Resources created by UNH OEHS for hazardous material shipping are used extensively nation-wide. Several UNH hazardous material shipping documents are widely recognized as standard reference material and are used by many other institutions. OEHS continued to create and update hazardous material shipping reference documents for the UNH research community in 2021, including updating training documents for shipment of infectious substances and shipment of methanol preserved specimens and dry ice.

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11.5 Hazardous Waste Management

OEHS provides hazardous waste management support to faculty, staff, and students at the Durham campus as well as the Manchester campus, UNH School of Law, Jackson Estuarine Laboratory, Coastal Marine Laboratory, Shoals Marine Laboratory, John Olson Advanced Manufacturing Center, and the UNH Automotive Garage. We manage US EPA, State of New Hampshire, and State of Maine regulated waste materials generated throughout the year as a byproduct of research, teaching, and facilities operations. In addition, the staff have been involved in several projects and initiatives to limit the university’s environmental liability by assuring proper transportation and disposal of hazardous materials and wastes and by reducing the quantity and toxicity of hazardous waste streams generated.

This year OEHS hazardous waste staff were involved in the following special projects:

• On June 23 – 24, the New Hampshire Department of Environmental Services (NHDES), Waste Management division, conducted a periodic regulatory inspection of the Durham campus to determine the university’s level of compliance with the State of New Hampshire Hazardous Waste Rules (Rules). The Rules codify the hazardous waste regulations required by state law for New Hampshire’s hazardous waste generators. OEHS has not yet received a final inspection report from NHDES, however, closing conference comments immediately following the inspection were generally excellent.

• Management of biohazardous waste and chemical waste from the university COVID-19 test lab.

• Managed the removal and disposal of bulk hazardous materials from the Arthur Rollins Treatment Plant which was constructed in 1935 and supplied potable water to UNH and the Town of Durham. The Arthur Rollins Plant was decommissioned after completion of a new water treatment plant which became operational in March of 2020.

• Managed the disposal of chemical contaminated materials and remediation wastes generated by UNH Facilities capital construction and renovation projects.

• Provided biohazardous waste management support for large scale university COVID-19 vaccine inoculation and rapid test clinics held at the Whittemore Center Arena.

11.5.1 Inventory Reductions

OEHS performed hazardous material inventory reductions throughout the University to increase safety and reduce liability in 2021, including but not limited to:

• Disposal of legacy and surplus chemical reagents from Spaulding (158), Rudman (257), Parsons (60), Arthur Rollins Water Treatment Plant (57), Morse (22), Kingsbury (122). 676 hazardous material containers were removed and disposed of. This represents the following chemical inventory reductions by building: Spaulding (11%), Rudman (3.4%), Parsons (0.3%), Old Water Treatment Plant (100%), Morse (1.2%), Kingsbury (5.2%).

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11.5.2 Summary of Hazardous and Universal Wastes Generated

As a result of various campus activities, the following statistics represent chemical and biological waste generation and disposal for the University in 2021.

Total Chemical and Biohazardous Waste generated:

• Chemical Waste: 13,008 kilograms

• Biohazardous Waste: 765 cubic feet

Quantities of hazardous chemical waste generated across campus departments and buildings are displayed in Figures 21 and 22 below. Overall, approximately ninety percent of the waste is generated through research and teaching activity, with operation and support functions contributing the remaining ten percent.

In 2021, the Chemistry Department (Parsons Hall) continued to be UNH’s largest generator of hazardous waste. Chemistry will continue to lead hazardous waste generation indefinitely due to the nature of the science. Teaching core curriculum chemistry courses for approximately fourteen hundred undergraduate science and engineering students each semester accounted for forty two percent (42%) of the Chemistry department’s waste generation.

The hazardous waste produced by Cooperative Extension (Lakes Lay Monitoring Laboratory) in Spaulding Hall and the Department of Natural Resources, and the Environment in James Hall is generated primarily by the research performed by two laboratories. These laboratories produced 88 percent and 84 percent of the hazardous waste generated at Spaulding and James Hall, respectively.

Annual waste production at the Co-Gen/Central Heating Plant is significant and is variable year to year due to periodic maintenance requirements thoughroutine waste streams such as used oils and contaminated wipers have been static.

The New Hampshire Veterinary Diagnostic Laboratory (NHVDL) generates histopathology chemical wastes related to veterinary laboratory services provided to New England region veterinarians, various NH state agencies, and state and local law enforcement agencies.

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Figure 21: Kilograms of Hazardous Chemical Waste disposed in 2021, by Building

Figure 22: Kilograms of Hazardous Chemical Waste Disposed in 2021, by Department

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11.5.3 Universal Waste

Universal Waste generation in 2021 saw a return to historic trends for fluorescent lamp and ballast recycling across the board. Fourteen circline lamps received for recycling last year indicating that this waste stream is negligible, and the graph has been deleted. HID lamps received for recycling dropped to a 10 year low of 186 showing the continuing trend of phasing out of this type of lamp. Lead acid battery recycling continues to see recycling rates well above the historical trend with three tons recycled this year versus a historical trend of about 1.5 tons. This is likely due to the regular replacement of batteries from back-up systems throughout the university. Figure 29 shows figures for the disposal of alkaline and other types of batteries from the University. Last year over 1000 pounds of batteries were sent for recycling.

Figure 23: Ballasts Removed from Campus from 2011 through 2021

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 TotalBallasts Removed PCB Lamp Ballasts 0 1,286 0 0 0 682 0 0 708.5 0 376 0 3,053Ballasts Removed Non-PCB Lamp

Ballasts 0 2,462 1,328 3,074 3,794 4,163 1,441 1,854 1,994 2,204 2,571 2,24124,885

0

5,000

10,000

15,000

20,000

25,000

30,000

Poun

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Ballasts Removed

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Figure 24: Fluorescent Lamps Disposed by OEHS from 2011 through 2021

Figure 25: Compact Fluorescent Lamps Disposed by OEHS from 2011 through 2021

39,993

48,15652,073

65,078

38,840

22,10525,420 28,213

25,250

42,329

23,497

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Feet

Calendar Year

Fluorescent Lamps Removed

2,400

4,329 4,143

6,496

3,878

2,120

3,438 3,469

2,847

4,381

3,424

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Num

ber o

f Lam

ps R

emov

ed

Calendar Year

Compact Fluorescent Lamps (CFLs) Removed

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Figure 26: Alkaline and other batteries recycled by OEHS from 2017 through 2021

Figure 27: U-Tube lighting disposed of by OEHS from 2011 through 2021

160

630

442365

790

307

401

172

403

261

0

100

200

300

400

500

600

700

800

900

2017 2018 2019 2020 2021

Poun

ds

Year

Alkaline and Other Batteries

alkaline

misc. batt.

1063

1300

514

705 691

872 896

613658

1285

714

0

200

400

600

800

1000

1200

1400

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Num

ber o

f Tub

es R

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ed

Calendar Year

U-Tubes Removed

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Figure 28: Number of HID Lamps Disposed by OEHS from 2011 through 2021

Figure 29 summarizes the pounds of lead-acid batteries disposed of between 2011 and 2021.

Since 2012 the quantity of lead-acid batteries has been reasonably consistent averaging 3488

pounds per year plus or minus 500 pounds. In 2019 a significant increase was seen in waste lead-

acid battery generation due to the University purchasing two solar power arrays and the

replacement of lighting units to use LED technology. 2021 saw a generation rate consistent with

the recent trend plus a COVID-19 “bump” in generation like that with the fluorescent lamps.

Figure 29: Lead Acid Batteries Disposed by OEHS from 2011 through 2021

208

638

327

582523

262

442382

250207 186

0

100

200

300

400

500

600

700

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Num

ber o

f Lam

ps R

emov

ed

Calendar Year

HID Lamps Removed

6,433

3,711 3,661 3,7282,946 3,265 3,279

3,828

12,008

4729

6,330

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Poun

ds

Calendar Year

Lead Acid Batteries Removed

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Routine maintenance of emergency lighting is the primary source of lead-acid batteries being recycled by the OEHS.

As existing emergency lighting fixtures are replaced with modern, efficient light emitting diode (LED) type designs we may see a reduction in lead-acid battery generation and an increase in other regulated battery types such as nickel-cadmium or lithium.

Figure 30 summarizes the Infectious Waste Disposal. In 2021 the amount of regulated biological waste generated by research and teaching activity returned to historic trends at 170 boxes. This was due to the COVID-19 Testing Lab being managed separately during the year.

Figure 30: Boxes of Infectious Waste Disposed of by OEHS from 2009 through 2021

12.0 Radiation, Laser and Magnet Safety

12.1 Radiation Safety

12.1.1 Program Information

UNH possesses a Type-A Broad Scope License issued by the New Hampshire Department of Health and Human Services, Radiological Health Section, to use and store radioactive materials. OEHS manages the associated Radiation Protection Program and ensures compliance with license conditions and applicable rules and regulations. OEHS periodically reviews and updates the Radiation Protection Program and the Radiation Safety Users Guide. OEHS distributes and reviews new and renewal applications for the use of radioactive material by University personnel and issues permits to Authorized Users as granted by the UNH Radiation Safety Committee (RSC).

0

100

200

300

400

500

600

700

800

900

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Boxes of Infectious Waste

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12.1.2 Training

State regulations require Radiation Worker training for incoming employees as well as Radiation Worker Refresher training once per year. Radiation Worker training prepares workers to use radioactive material and is a 3-hour training that includes on-line through instructor-led elements. Six students, staff, and faculty completed Radiation Worker training, and 36 students, staff and faculty participated in Radiation Worker Refresher training on-line. Live presentations and on-line trainings are revised annually by the Radiation Safety Officer (RSO). Radiation Worker Refresher is updated annually as needed, to reflect compliance with state regulations.

For those students, staff, or contractors that need to access radioactive laboratories, but do not use radioactive material, Radiation Awareness training is conducted.

Training for UNH contractors is conducted via an instructor-led course. In addition to the basics of radiation awareness this training includes elements of laser, magnet, x-ray, laboratory, and biological safety.

12.1.3 Radiation Protection Program Maintenance

OEHS maintains the Radiation Protection Program (RPP) manual and the Radiation Safety Users Guide (RSUG). These documents are revised at least every two years as a best management practice. The RPP was updated with a new OEHS organization chart and a new delegation of authority letter from President Dean. The RSUG had minor edits and formatting corrected.

12.1.4 Audit and Regulatory Review Third Party Audit

State regulations require an annual review of the radiation safety program. UNH contracts with

Clym Environmental Services, LLC each year to review the radiation safety program at UNH. The

annual review includes a site walk of laboratories, wipe tests for possible contamination, and a

document review. The 2021 audit suggested minor improvements to radiation safety program

and these suggestions are being implemented.

12.1.5 Radiation Safety Monitoring Instruments

OEHS tracks the annual calibration of survey instruments, such as Geiger counters, and Sodium Iodide detectors. Gas Chromatographs (GC) and Liquid Scintillation Counters (LSC) are inventoried twice per year for the sealed sources internal to the machine. OEHS has eight survey instruments and one LSC. Permitted laboratories have three survey instruments, seven GCs, and six LSCs.

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Table 13 Radiation Safety Monitoring Instruments Maintained by OEHS

Model Number Instrument Type Manufacturer Calibration

RSO-5 Bicron Annual

ESP NaI Meter Eberline Annual

ASP2E Neutron Monitor Eberline Annual

ASP2E Eberline Annual

Gr-130 Exploranium Annual

3 GM Counter Ludlum Annual


3-241R Ludllum Annual


14C-084R GM Counter Ludlum Annual



12.1.6 Occupational and Public Doses- Dosimetry Program

OEHS manages a dosimetry program to track doses from external radiation for applicable faculty, staff, and students. State regulations dictate individual exposure limits in one year. OEHS tracks these doses each quarter to assure compliance with these regulations. This program switched from a bi-monthly to quarterly exchange program in 2019. OEHS interprets results of dose reports for Authorized Users and Radiation Workers, Health Services staff, and Veterinary Technology staff and students. OEHS also tracks area monitors in Space Science, Veterinary Technology and the OEHS radioactive waste room. Area monitors are dosimeters placed in hallways adjacent to radioactive materials work or storage locations to track the potential dose to non-radiation workers and the general public. OEHS issued annual occupational dose history reports to Radiation Workers, which documents doses for the previous year. OEHS processed 12 termination dose history reports for individuals who have ceased using source of radiation at UNH. Typical types of dosimetry badges and rings are shown in Figure 31, below

Figure 31:Typical Dosimeter

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For Veterinary Technology there have been 17 dosimeters exchanged every three months. Health Services had 4 dosimeters exchanged every three months and Authorized User Radioactive Permits had 23 dosimeters exchanged every three months.

12.1.7 Surveys and Monitoring

Surveys were conducted quarterly in 2021. The RSO, or designee, performed surveys in laboratories three times and Clym Environmental performed surveys once per year as a third-party audit. Surveys include monitoring with a Geiger counter and conducting wipe tests with a filter paper to identify surface contamination and a review of lab records. No items of non-compliance were found during these routine surveys.

12.1.8 Leak Test Procedures

Sealed sources are solid forms of radioactive materials that do not normally pose a threat of contamination. In rare instances, these sources may leak radioactive contamination, therefore leak tests are performed on sealed sources at a frequency prescribed by the State of New Hampshire, Radiological Health Section. There are 125 active sealed sources on campus and all sealed sources are inventoried twice per year.

OEHS completed of 74 leak test evaluations across the UNH campus. The RSO, or designee, performed forty- eight (48) three-month leak tests on alpha sources.

Semi-annual leak tests are performed on beta, gamma, and neutron sources as required by the State of New Hampshire, Radiological Health Section. Twenty-six bi-annual leak tests were performed by the RSO, or designee for OEHS, in 2021.

12.1.9 Waste Management

OEHS manages the pick-up, storage, and disposal of radioactive waste including Dry Active Waste, (DAW), Liquid Scintillation Vials, and other radioactive materials as necessary.

Liquid scintillation vial waste is deregulated and is stored until a 55-gallon drum is full and shipped out for incineration. In 2021, OEHS picked up approximately 23-gallons of liquid scintillation vial waste.

Dry active waste is contaminated solid material such as gloves, absorbent pads, and paper towels generated in laboratory activities using long-lived radioisotopes. OEHS picked up approximately 20-gallons of DAW in 2021. DAW is stored on site for disposal on an approximate three-year cycle. The next estimated DAW waste disposal year is 2022.

OEHS also manages disposal of naturally occurring compounds such as uranyl acetate, thorium nitrate, and uranium. These are generally licensed materials when purchased and need to be disposed of as radioactive waste when no longer needed. OEHS picks up these materials from principal investigators and stores the material for subsequent shipment for disposal as radioactive or mixed waste.

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12.1.11 Waste Minimization

OEHS maintains a waste minimization program by instructing researchers to limit long-lived radionuclides that need to be shipped for burial. Waste minimization techniques are taught to Radiation Workers by the RSO, such as excising small pieces of contaminated bench pads rather than discarding the whole pad after each experiment.

12.1.12 Radon Management Program

Radon is a radioactive gas emitted from rock or soil, which may be hazardous to breathe into the body. OEHS maintains a program to monitor for radon in any new building, rental property, or any large-scale construction project to a building. Charcoal vials (Figure 32) placed in the building for the weekend are then sealed and sent to an outside laboratory for analysis.

As an example, in 2020 radon testing was requested for a residential property located at Mast Road in Durham, New Hampshire. The property was set-up as a resource for COVID-19 pandemic quarantine and isolation response.

Figure 32: Radon sampling media

12.2 Magnet Safety

12.2.1 Program Information

UNH teaching and research programs utilize instruments that generate large, static magnetic fields such as Nuclear Magnetic Resonance (NMR) spectrometers and Superconducting Magnets (SM). In response to the hazards posed by such instruments, UNH has implemented a Magnet Safety Program (MSP) as a best practice. The program elements include a safety manual, training, standard operating procedures (SOPs), and area audits. The MSP falls under the purview of the Radiation Safety Committee.

12.2.2 Training

A NMR training program was developed between OEHS and the University Instrumentation Center (UIC). Students, staff, and faculty take an on-line course through UNHCEMS® for part 1 of their training. The UIC then trains the individual on the SOP and issues a key to the NMR room. Refresher training is tracked by the RSO each September. Thirty-three students, staff, and faculty were trained in Magnet Safety in 2021.

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12.2.3 Registration and Instrumentation

Magnet registration is required by the MSP. For ease of access for magnet owners a module was created in UNHCEMS® to register magnets with OEHS. There are four active superconducting magnets or NMR units on campus, as summarized in Table 14. Figure 33 shows a typical superconducting magnet in use at UNH.

Figure 33: Superconducting magnet located at UNH Durham

Table 14 Magnet Instrument Inventory 2021 Model

Type

Strength Tesla

Vertical Distance to 5g line

Horizontal Distance to 5g line

Status Location

Oxford AS400/54

NMR

9.395 1.49 0.88 Active Parsons Hall W124

Oxford AS500/51

NMR

11.744 1.84 1.31 Active Parsons Hall W124

American Magnetics

NMR

5, 7 max 92-inches 72-inches Active Demeritt Hall 103

High Resolution NMR

7.05 1.7 m 2.3 m Active Demeritt Hall 103

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12.2.4 Surveys and Audits

Visual surveys are conducted twice per year in the two superconducting magnet laboratories. Surveys are performed by the RSO or designee. The State of New Hampshire does not inspect superconducting magnets used for research. Survey inspection items include, proper area postings, updated operating procedures and adequate designation of the the 5-gauss line. Magnetic fields are measured in units of magnetic induction, such as gauss. The 5-gauss line designates how close someone with a metallic implant such as a pacemaker can get to the magnet without any harm.

12.2.5 Program Maintenance

The MSP is updated every two years by the RSO and reviewed by the Radiation Safety Committee. The on-line training program through UNHCEMS® is updated once per year in preparation for refresher training. SOPs are updated by the magnet laboratories annually.

12.3 X-Ray Safety

12.3.1 Program information

UNH is committed to maintaining the highest quality X-Ray Protection Program (XPP).. Likewise, UNH commits to full and complete compliance with all relevant requirements in the State of New Hampshire Rules for the control of radiation. The XPP is designed to control operations conducted at UNH Research and Educational Facilities which may result in the potential exposure of UNH personnel, members of the general public, and/or the environment to X-Ray Radiation.

The University of New Hampshire’s commitment to the XPP is based on the fundamental principle that levels of radiation to be used, and exposures to all sources of ionizing radiation, are to be maintained As Low As Reasonably Achievable (ALARA).

The XPP is administered by the UNH RSO and supported by OEHS and the UNH Radiation Safety Committee. UNH has X-Ray diffraction machines and electron microscopes, as well as diagnostic machines for the Veterinary Technology program.

12.3.2 Training

All students, staff, and faculty who use X-Ray producing machines take X-Ray Safety training on-line through UNHCEMS®. Refresher training is offered once per year based on state regulatory requirements. Thirty-five people completed X-Ray Safety or X-Ray Refresher training in 2021.

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12.3.3 Registration and Instrumentation

State registration and payment is required to operate an X-Ray producing machine on campus. All X-Ray producing machines are registered each summer and the certificate of registration is posted in the laboratories. An instrumentation inventory is maintained by the RSO and summarized in Table 15 below.

Table 15 X-Ray Machines Registered at UNH in 2020

Model Room or Area Location Type

Shimazdu XRD-6100 Parsons N123

Diffractometer

Bruker-Axs GADDS Parsons N123

Diffractometer

Siemens- Kristalloflex

D-5000 James 284

Diffractometer

Kratos Analyti cal

Supra Parsons W118

X-Ray Fluorescence

ZEISS Incidental to use

Parsons NB17AC

Electron Microscope

Tescan Lyra 3 GMU Parsons NB17AD

Electron Microscope

Teltron Tabletop Model

Demeritt 317

Diffractometer (X-Ray)

Ultra EPX-F1200 Barton 132

Diagnostic

Sedecal R108 Barton 119C

Diagnostic: General Purpose, Animal

Sirona Heliodent Plus Barton 119E/F

Diagnostic: dental, animal

All Pro Imaging Provectav Barton 205

Demo only: dental, animal

12.3.4 Surveys

X-Ray laboratories were surveyed twice in 2021. The RSO, or designee, completes these surveys, totaling twenty-two (22) X-Ray surveys in 2021. For cabinet machines, surveys include testing the interlocks. Tests are completed for leakage of radiation for all X-Ray producing machines and postings are verified.

12.3.5 Postings

Signage is posted per State of New Hampshire Regulations in X-Ray laboratories including the Notice to Employees (Form RHS-5), which provides workers contact information to notify the state of unsafe conditions, the Certificate of Registration of the machine, and the Standard Operation Procedure to properly use the machine.

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12.3.6 Audits and Regulatory Reviews

Clym Environmental surveys the X-Ray laboratories as part of the annual third-party audit of the program. No items of non-compliance were found in the x-ray program in 2021. The State of

New Hampshire, Radiological Health Section audits the UNH XPP once every three-five years. UNH was last audited by the State in 2015.


The XPP is revised every two years. Dosimetry records are analyzed every three months for Veterinary Technology faculty and students. Additional surveys are conducted if machines are repaired.

12.4 Laser Safety

12.4.1 Program information

The Laser Safety Program (LSP) presents guidelines to protect UNH employees and students from the hazards associated with lasers and laser system operations. The intent of this program is to ensure the safe use of lasers through engineering and administrative controls. This objective shall be accomplished by identifying potential hazards, providing recommendations for hazard control, and training laser operators and incidental personnel. The LSP manual outlines the laser safety recommendations for UNH and is based on the American National Standard for the Safe Use of Lasers, or American National Standards Institute (ANSI) standard guidelines. There are currently no state regulations that pertain to laser safety, although the Radiological Health Section would like to regulate lasers in the future. A typical laser set up with posted SOP at UNH is shown in Figure 34.

Figure 34: Picture of a laser device at UNH

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LASERS BY BUILDING

Lasers Class 3B Lasers Class 4

12.4.2 Training

On-line training through UNHCEMS® is offered for Laser Operators. Laser Operator training includes hazard identification, proper signage, use of protective eyewear, laser registration requirements, and SOP requirements. All laser trainings are updated annually. In 2021, OEHS Laser Operator training was completed by six students, staff, and faculty. Live and on-line Laser Awareness training is offered for those that need to enter laser laboratories, but do not use lasers. Twenty-two students, staff, and contractors completed Laser Awareness training in 2021.

12.4.3 Registration and Inventory

All active and inactive lasers are registered with OEHS. OEHS has an inventory of 42 class 3B and class 4 lasers, of which 7 are in active use. Figure 33 represents the number of lasers in each building on campus. The Laser program has been determined by both Clym Environmental and the Radiation Safety Officer as an area that needs more attention. This program will undergo a full internal audit in the future.

9

3

5

6 2

2

1

2

2 1

2 1 1 1 1 1

Figure 35: Total Lasers on Campus by Building (includes Active Lasers and Lasers in storage)

12.4.4 Standard Operating Procedures

Written SOPs are required for both the regular use and alignment of class 3B and 4 lasers. SOPs are updated by the Authorized User, approved by the Laser Safety Officer, and signed by the students and faculty that will be using the laser. The SOP should be referenced each time the laser is used.

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Some examples of the safety precautions in a laser SOP include: validation of required training; removal of all reflective jewelry, watches, and belt buckles; use of laser-in-use lighted signs; securing all laser safety curtains or barriers; and proper use of required personal protective equipment.

12.4.5 Personal Protective Equipment

Laser safety eyewear and laboratory coats are examples of PPE. Laser safety eyewear has an optical density and wavelength specific to the laser. The calculated wavelength and optical density are described in the SOP for Authorized Users. Laboratory coats are recommended with ultraviolet lasers to protect the skin. Flame retardant laboratory coats are recommended for Class 4 lasers.

12.4.6 Surveys

Laser Safety surveys are conducted twice per year in all laser laboratories, once by the LSO and once by a third party. Survey inspection items include: proper registration; current training; appropriate PPE use; SOPs posted; Appropriate curtains and/or barriers; and accident / incident reporting and documentation.

Significant findings are reviewed by the Radiation Safety Committee.

12.4.7 Audits

Third party audits are performed every fourth quarter by Clym Environmental. Similar to laser surveys, inspection items are reviewed and an interview is completed with the Authorized User. Discrepancies identified during any audits are immediately addressed.


The LSP is reviewed and approved by the Radiation Safety Committee every two years as a best practice. The LSP was updated in 2020 with a new OEHS organization chart, a new delegation of authority letter from the president, and updated formatting.

13.0 UNH at Manchester

13.1 Safety Committee

The charge of the Environmental Health and Safety Committee is to assure a safe work

environment for faculty, staff and students and visitors through the creation and maintenance of

effective health and safety programs. It is the responsibility of the Committee to establish

appropriate health and safety policies, programs, and procedures in accordance with federal

regulations and guidelines that cover workplace safety and emergency preparedness. The UNH

Manchester Emergency Health and Safety Committee (EHSC) met in 2021 to address pertinent

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health, safety, and emergency matters for the UNH Manchester campus. A few of the

accomplishments of the group are listed below:

• COVID-19 surveillance testing was performed for all students, staff, and faculty accessing

UNHM Facilities

• COVID-19 mitigation cleaning protocols were continued throughout 2021

13.2 UNHCEMS® - Chemical Inventory and Training

Chemicals maintained at the University of New Hampshire Manchester’s campus are recorded and tracked using the UNH Barcode system, which links chemical containers to the UNHCEMS® online inventory program.

Data maintained in UNHCEMS® regarding the chemical inventory at UNH at Manchester from 20010 through 2021 is summarized in Table 16, below.

Table 16 Chemical Inventory Statistics for University of New Hampshire Manchester

Year Removed Containers Added Containers Active Containers

2010 68 36 577

2011 12 11 576

2012 44 38 570

2013 29 48 589

2014 62 32 559

2015 58 59 560

2016 31 60 557

2017 14 150 693

2018 29 134 798

2019 97 162 863

2020 18 84 927

2021 21 161 1,067

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13.3 Contingency Planning

A contingency plan was prepared for the University of New Hampshire Manchester campus in 2016 and (updated in 2021). The plan was created to establish preparedness, planning, spill response and spill notification procedures for hazardous materials at this campus. The University of New Hampshire at Manchester campus does not meet the minimum threshold quantities requiring a formal ICP or SPCC as prescribed by the US EPA Oil Pollution Prevention Regulations (40 CFR Part 112) and Hazardous Waste Regulations (40 CFR 260-265), the New Hampshire Hazardous Waste Rules (Env-Hw 100-1100) or the OSHA Emergency Response requirements for facilities engaging in hazardous waste operations (29 CFR 1910.120). However, a modified ICP was prepared as a best management practice for responding to spills for the limited quantity of hazardous materials stored at this campus.

Included within the contingency plan is a list of emergency contacts for the UNH Manchester facility and city and state agencies, a spill release response reporting quick reference summary, Initial Spill/Release Response Flow Chart and Spill Response Reporting Flow Chart, and a copy of the Emergency Assistance Agreement Response Form signed by the City of Manchester Fire Chief. The plan was amended in 2021 to include changes to local contacts and new UNH contacts.

14.0 UNH Franklin Pierce School of Law

14.1 Emergency Health and Safety Committee

The UNH Franklin Pierce School of Law established a formal EHSC in 2015. The charge of the Committee is to assure a safe work environment for faculty, staff, students and visitors through the creation and maintenance of effective health and safety programs. The EHSC reports to the UNH Law School Dean and the Office of the Provost and Vice President for Academic Affairs on matters related to emergency preparedness, industrial hygiene, and workplace safety compliance. Specific tasks include:

• Develop, review, and update written programs and procedures to ensure compliance with OSHA, New Hampshire Department of Labor and other applicable regulations, and recognized consensus safety standards;

• Serve as an advisory body to the UNH Environmental Health and Safety Committee on policies and procedures to ensure the health and safety of all faculty, staff, students, and visitors at UNH-M; and

• Obtain and analyze available data on past injuries and illnesses, identify trends, and suggest appropriate corrective actions.

The EHSC is a deliberative body that is representative of the Franklin Pierce community and includes members from academic and administrative divisions on campus. It is the committee's responsibility to advise the Dean, and to administratively coordinate the various safety-related

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efforts of the university community. Full voting membership of the EHSC includes the Facilities Manager, the Security Supervisor, the Reference and Public Services Librarian, the SR Human Resource Assistant, the Information Technology Administrator, the UNH Director of Environmental Health and Safety and the UNH Assistant Director of Emergency Management. Chair and Vice-Chair are elected for 3-year terms with a majority vote. The EHSC Chair is a member of the UNH Environmental Health and Safety Committee.

14.2 Other Accomplishments

Other accomplishments completed by the UNH Franklin Pierce School of Law EHSC in 2021 include, but are not limited to:

• The school’s Emergency plan is available via “Quick Link” from the UNH Law website.

• Captain Lee and Sergeant MacLennan of the UNH Police department gave an active shooter training to law school staff.

15.0 Emerging Issues

15.1 Staffing Disruptions

USNH institutions were challenged in 2021 with a high number of retirements and resignations; this staffing disruption affected EHS programs directly as experienced staff retired or resigned and indirectly as talented faculty and staff who helped maintain a culture of safety left USNH. These staff disruptions could have a significant effect on USNH EHS programs. How effectively these staff resources are replaced with qualified replacements and the extent to which staff disruptions continue will determine overall impact on USNH EHS operations. 15.2 COVID-19 Management and Response

OEHS will continue to dedicate staff resources to managing campus issues related to the global pandemic. Committee work will continue in 2022 to improve and update response efforts. OEHS efforts have largely focused on support of essential field and laboratory research programs, and it is likely these efforts will continue in 2021. OEHS will continue to support operation of the COVID testing lab wit hazardous waste management, biosafety support services, and laboratory safety services.

15.3 UNH Ice Rink Upgrades

In 2022 UNH has embarked on the construction of a new and upgraded ice rink. This new rink will still utilize Ammonia for refrigeration. As such, EH&S will work with campus stakeholders to maintain compliance with the USEPA for Ammonia Refrigeration Systems by ensuring proper management plans are in place for safely maintaining the refrigeration system and responding to emergencies.

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15.4 UNHCEMS® 3.0 Development

OEHS staff are integral members of the UNHCEMS® development team. Through 2021 the OEHS UNHCEMS® Administrator and others in the OEHS office have been supporting the development of UNHCEMS® 3.0. UNH OEHS works with the UNH Project Manager (RCC) to assist in guiding the design of the new UNHCEMS®. This multi-year project includes project team meetings to design, build and test the latest version of UNHCEMS®. This effort will be a from scratch recode and design of UNHCEMS®. UNH OEHS staff will be working with members of the Research Computing Center and the UNH Innovations team.

16.0 Communication and Outreach

OEHS uses many ways to communicate our mission to the campus. The department also provides invaluable information to the general public. This is accomplished in the form of a departmental website (Figure 36), face-to-face and group meetings, electronic communications, telephone consultations, on-site investigations, group trainings, and other effective communication methods.

Figure 36: OEHS Home Page

The minutes of the Chemical, Occupational, and Radiation Safety meetings are posted on the website for full public disclosure of our activities. OEHS staff members serve as representatives on these regulatory committee meetings, and attend other meetings of interest to the campus, such as building construction and renovation meetings, the Energy Task Force, the Ecosystems Task Force, the University Emergency Group, as well as ad-hoc meetings when new issues arise.

OEHS produces and distributes many pamphlets and educational materials that cover a wide variety of health and safety topics. As a general practice, the technical experts in OEHS share their programs as much as possible.

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17.0 Mechanisms to Measure Compliance

UNH utilizes several mechanisms to assure the campus is meeting the elements and objectives of the campus EH&S programs discussed in this report. These include outside audits, regulatory inspections, technical committee oversight, OEHS program review and USNH EH&S Council review. Examples are highlighted below.

17.1 Industrial Hygiene

Indoor air quality and toxic material exposure assessments are conducted by OEHS, outside consultants, or by the campus Worker’s Compensation Insurer depending on the complexity of the issue. Data collected during assessments are compared to current regulatory exposure limits and recommended industry guidelines. The New Hampshire Department of Labor reviews notifications regarding proposed asbestos abatement and is the regulatory agency responsible for governing abatement in New Hampshire. 17.2 General Safety

OEHS and the campus Worker’s Compensation Insurer conduct quarterly independent safety audits of targeted areas. OEHS utilizes injury and illness trending data compiled by UNH’s Workers Compensation insurer to focus safety initiatives. OEHS works with colleges and departments to maintain an electronic environmental health and safety training database for affected faculty, staff, and students. This centralized record keeping process enables OEHS and/or managers to generate queries of individual staff or area departments that are due for safety training. These reports aid in the scheduling of safety training and ensure that all necessary training is completed. Procedures for particularly hazardous work such as hot work, confined space entry, and asbestos and/or lead abatement require a reporting procedure that involves regular communication and oversight from OEHS with additional assistance from the Durham Fire Department and State agencies, as necessary.

17.3 Fire Protection

Both the Durham Fire Department and the State Fire Marshal’s Office conduct fire and life safety inspections of campus buildings. Fire suppression and fire alarm systems are tested and certified by outside consultants.

17.4 Occupational Health and Medicine

Medical screening and surveillance programs are implemented by departments utilizing the services of either UNH Health and Wellness or outside occupational health services organizations. Faculty, staff, and student compliance with the animal handler medical surveillance program is reviewed jointly by OEHS and the Office of Research Integrity Services on a monthly basis.

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17.5 Disaster Preparedness

UNH has implemented an Emergency Action and Procedures Plan that outlines procedures to be followed by the campus community for responding to and recovering from fires, hazardous materials spills, and major accidents. Specific procedures to follow for fire evacuation are listed

in the plan. Nobis Engineering, Inc. was hired to conduct a thorough review of the UNH Integrated Contingency Plan to ensure compliance with federal and state regulations.

OEHS liaises with UNH Police for annual reviews of Emergency Procedures and Action Plans.

17.6 Diving Safety

All aspects of the UNH research diving program are reviewed annually by the UNH Diving Safety Control Board. 17.7 Biological Safety

The UNH IBC reviews and approves all biohazardous material use on campus, including use of recombinant and synthetic nucleic acid molecules, for compliance with the National Institutes of Health Guidelines. OEHS conducts laboratory audits to assure proper biosafety procedures are being followed in the laboratory. Laboratories using human source materials are kept in compliance with the OSHA Bloodborne Pathogens Standard through training, strict use of Universal Precautions, sharps surveys and Hepatitis B vaccine offerings.

17.8 Hazardous Materials Inventory and Reporting

The U.S. Department of Transportation and the Federal Aviation Administration perform unannounced inspections and audits of the shipping program as part of a regional initiative to enforce hazardous materials shipping regulations at colleges and universities.

17.9 Hazardous Waste Management

OEHS provides regular oversight and review of laboratories and shops that generate and store hazardous waste. The NHDES and the U.S. Environmental Protection Agency conduct unannounced inspections of the hazardous waste management program at colleges and universities. OEHS staff conducted a review of the CHWAA Preparedness, Prevention and Contingency Plan, the Hazardous Waste Transporter Contingency Plan, and the Central Accumulation Area Security Plan.

17.10 Radiation Safety

Radiation safety oversees both ionizing and non-ionizing radiations and inspects all laboratories that contain radioactive material quarterly, performs contamination surveys, radiation surveys and compliance audits, and ensuring all laboratories continue to meet all license conditions, as well

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as all state and federal regulations. The Radiation Safety Program is audited annually by an outside consultant. Results of the audit are shared with the Radiation Safety Committee and the Committee approves any changes to the Radiation Protection Program recommended by the audit consultant.

17.11 Laboratory Safety

OEHS receives chemicals ordered by laboratory chemical users at the university. Upon arrival, these chemicals are barcoded, entered into CEMS and delivered to the chemical user for use. OEHS additionally performs laboratory chemical fume hood evaluations on an annual basis as well as after disruptive events, which could include unplanned power outages, repair completions, preventive maintenance, and user requests. In 2021, during both chemical deliveries and fume hood evaluations, any observations of laboratory safety issues were addressed in coordination with the laboratory users in lieu of formal inspections due to the pandemic.

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* Heat Stress n n

* Illumination n n


















* Dosimetry n n

* Magnet Safety n n

* X-Ray Safety n n


* Laser Safety n n




Not Applicable n


UNH Compliance Status December 2020 and December 2021

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Program Elements 2020 20213.3.3.1.2.4 Occupational Health and Medicine* Respirator Medical Questionnaire n n















3.3.3.2 Hazardous Materials & Environmental Management3.3.3.2.2.1 Hazardous Waste Management* Hazardous Waste Management Program n n







3.3.3.2.2.2 Hazardous Materials Inventory and Reporting* Chemical Environmental Mgmt System/Inventory System n n













Annual Report - December 2020UNH Compliance Status December 2020 and December 2021


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1

USNH Environmental Health and Safety Annual Report – 2021 University System of New Hampshire Central Offices

1. MISSION STATEMENT

The University System of New Hampshire’s Central Office is committed to providing and maintaining a safe environment for its employees and visitors. USNH focuses on fire and life safety, hazardous material management, accident prevention, industrial hygiene, and safety and health training. The University System of New Hampshire Central Office complies with all required federal, state and local statutes and with USNH Policy.

2. AUTHORITY

USNH Board of Trustee Policy (BOT VI.F.1.3) The Presidents, in collaboration with the Chancellor (currently Chief Administrative Officer), shall establish procedures to ensure the prudent management of environmental health and safety in compliance with applicable state and federal laws. Those procedures shall include coordination with a USNH Council on Environmental Health and Safety, with representation from each component institution. These procedures shall also include, where appropriate, a mechanism for measuring compliance through appropriate means including periodic environmental audits. The Chief Administrative Officer shall coordinate presentation to the Audit Committee of an annual report describing the state of the University System’s environmental health and safety efforts at each institution, including the findings of any environmental audit conducted during the reporting period.

3. CAMPUS PROGRAM ELEMENTS

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2

The USNH Joint Loss Management Committee provides support for the System Office at 5 Chenell Drive, Concord, NH. Meetings occur quarterly and include representation from multi departments. Minutes of the System Office Joint Loss Management Committee are taken, reviewed and maintained.

4. INJURY AND ILLNESS PREVENTION

A. Industrial Hygiene

This program is not applicable at the University System Central Offices

B. General Safety

Injury control is the primary issue for the University System Central Offices. Accident investigation is performed when an illness/injury report is filed with the office of Human Resources. Recommendations are made, if necessary, to prevent recurrence. Workplace Safety Management Consultants from MEMIC are available to assist with accident investigations and risk management oversight for employees. Identify and reduce potential risks for office COVID-19 transmission by spacing and limiting numbers of employees in the office. Adding physical barriers and providing space for social distancing.

C. Radiation Safety

This program is not applicable at the University System Central Offices.

D. Fire Protection

The USNH Facility Supervisor performs annual site and safety inspections of Central Offices at 5 Chenell Drive. Part of the inspection addresses fire and evacuation routes and planning procedures. Evacuation drills are held annually. The fire alarms are tested annually by FiveKph, LLC (property owner), Thomas H. Balon Jr. 15 Merrill Street, Manchester NH 03103.

E. Occupational Health and Medicine


F. Disaster Preparedness

USNH has emergency evacuation procedures which address evacuation in case of disasters. USNH Central Offices participate in the UNH Alert system administered by the UNH Police Department. This system allows USNH to contact staff during an emergency by sending text messages to staff emails, cell phones, pagers and blackberries/smart phones.

G. Biological Safety

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3


H. Diving Safety


5. HAZARDOUS MATERIALS & ENVIRONMENTAL MANAGEMENT

A. Hazardous Waste Management

The USNH Central Offices deals with a small amount of hazardous waste. Identifiable waste streams include fluorescent light bulbs, copier machine and laser printer toner and outdated computer equipment. The Facility Supervisor is responsible for the disposal of all of the above mentioned items. Electronic equipment is disposed of via the UNH IT Safe Electronic Equipment Disposal (SEED) program.

B. Hazardous Materials Inventory and Reporting

There are janitorial cleaning supplies located on site. Safety Data Sheet information is posted on site and janitorial employees are trained on the proper use of cleaning supplies.

6. MECHANISMS FOR COMPLIANCE

The USNH Facility Supervisor ensures the compliance with safety policies by performing site evaluations and contracting with environmental specialists to assist with internal audits. Annual items reviewed include: facility safety issues and procedures, evacuation drills, (including the conducting of drills), the posting of emergency exit signs and diagrams, fire extinguishers inspections, and the removal of hazardous materials as outlined in 5A. The Facility Supervisor provides the System Office Joint Loss Management Committee regular updates on the results of the evaluations and audits and on efforts to mitigate any items of concern noted in the reports.

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USNH Compliance Status December 2020 and December 2021 Program Elements 2020 2021


3.3.3.1.2.1 Industrial Hygiene * Asbestos Abatement

* Lead Abatement * Hearing Conservation * Indoor Air Quality

* Personnel Exposure Monitoring for Toxic Materials * Respiratory Protection * Hazard Communication (GHS) * Heat Stress * Illumination

3.3.3.1.2.2 General Safety * Confined Space * Fall Protection

* Ergonomic Evaluation * Lock-Out/Tag -Out * Accident Investigation * Powered Industrial Trucks * Cranes & Hoists * Mobile Elevating Work Platform * Dig Safe Program * Bloodborne Pathogens * Workplace Safety Inspections

3.3.3.1.2.3 Radiation Safety & Laser Safety * Radioactive Material License

* Radiation Safety Committee * Radioactive Material Inventory * Radiation Safety Manual * User/Awareness Training * Radiation Safety Laboratory Inspections * Dosimetry * Magnet Safety * X-Ray Safety * Radioactive Waste Management * Laser Safety

LEGEND Program in place

Program undergoing review, improvement, or under development

Program not in place

Not Applicable

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USNH Compliance Status December 2020 and December 2021 Program Elements 2020 2021

3.3.3.1.2.4 Occupational Health and Medicine * Respirator Medical Questionnaire * Hepatitis B Vaccination * Animal Handlers Occupational Health

3.3.3.1.2.5 Integrated Contingency Planning * Aboveground Storage Tank Program * Underground Storage Tank Program * Integrated Contingency/Spill Prevention Control and Countermeasures Plan

3.3.3.1.2.6 Biological Safety * Institutional Biosafety Committee * Biosafety Manual * Recombinant DNA Registration * Biosafety Laboratory Surveys * Inventory of Infectious Material * FDA Food Biosecurity Application

3.3.3.1.2.7 Diving Safety * Diving Safety Control Board * Diving Safety Officer * Diving Safety Manual


3.3.3.2.2.1 Hazardous Waste Management * Hazardous Waste Management Program * EPA Identification Number * Faculty/Staff/Student Training * Contingency Plans for Central Accumulation Area * Satellite Accumulation Area Inspections * Universal Waste Management * Biohazardous Waste Management

3.3.3.2.2.2 Hazardous Materials Inventory and Reporting

* Chemical Environmental Mgmt System/Inventory System * DEA Controlled Substances Inventory * DHS Chemicals of Interest Inventory * Community Right To Know/SARA Title II * Safety Data Sheets * Chemical Safety/Hygiene Plan * Chemical Laboratory Inspections * Chemical Safety Committee * Title 5 Air Permit * Stormwater Management Plan * Refrigerant Management Plan * Water Quality Permits * Hazardous Materials Shipping

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Item VII. B. Self-assess Audit Committee Effectiveness

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Additional expertise - technology

Better understanding of the business (strategy and risks)

Greater diversity of thinking, background, and experience

Deeper engagement by committee members

Additional training to committee members

Additional reporting to the committee

What would most improve the Committee's overall effectiveness?

Response frequency (multiple selections per respondent possible)

0

0

0

1

1

1

4.4

3

4.5

0

3.6

7

4.0

0

4.0

0

Staying up-to-date on changes impacting the

organization.

4.5

7

4.5

0

4.0

0

5.0

0

4.5

0

Overseeing assigned portions of enterprise risk

management.

4.4

3

4.5

0

3.6

7

5.0

0

4.5

0

Prioritizing the meeting agenda to focus on the most important issues.

4.5

7

4.6

7

4.3

3

4.0

0 4.5

0

Questioning management, internal auditors, and

independent auditors about the quality of the control

environment.

4.2

9

4.3

3

3.3

3 4.0

0 4.5

0

Challenging management and applying skepticism.

4.4

3

4.5

0

3.6

7

4.0

0

4.0

0

Understanding how USNH publicizes, monitors, and enforces its written codes

of conduct.

4.2

9

4.3

3

4.0

0

5.0

0

5.0

0

Determining whether USNH has an effective compliance

and ethics program.

4.3

3

4.5

0

4.0

0

5.0

0

5.0

0

Assessing whether USNH has adequate processes and

controls to prevent and detect fraud.

4.7

1

4.6

7

4.3

3

4.0

0

5.0

0

Overseeing financial reporting and disclosures.

4.4

3

4.3

3

4.0

0

4.0

0

5.0

0

Fostering relationships with management, internal

auditors, and independent auditors.

4.5

0

4.6

7

4.6

7

5.0

0

4.5

0

Assessing the internal auditor’s performance.

4.7

1

4.8

3

5.0

0

5.0

0

5.0

0

Encouraging a tone at the top that conveys basic

values of ethical integrity, legal compliance, and

strong financial reporting and control.

4.7

1

4.5

0

4.3

3 5.0

0

5.0

0

Monitoring conflict of interest policies and

procedures.

4.5

7

4.8

3

4.3

3 5.0

0

5.0

0

Assessing the independent auditor’s performance.

4.8

6

4.6

7

4.0

0

5.0

0

5.0

0

Conducting open and candid discussions with the

independent auditors on tone and culture.

2018

2019

2020

2021

2022

N = 7 6 3 1 2

4.00− Most of the Time

Indicator Ratings by Year 2018−2022

USNH Board of Trustees | Audit Committee Evaluation 2022

MEMBER Assessment of Committee Effectiveness | Scale: 1.00− Not Effective to 5.00− Highly Effective

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1 1 1 1

2

1 1 1

Prioritizing the meetingagenda to focus on themost important issues.

Questioning management,internal auditors, andindependent auditors

about the quality of thecontrol environment.

Challenging managementand applying skepticism.

Understanding how USNHpublicizes, monitors, and

enforces its writtencodes of conduct.

Staying up-to-date onchanges impacting the

organization.

1 11

2 2

1 1

Assessing whether USNHhas adequate processesand controls to prevent

and detect fraud.

Overseeing assignedportions of enterprise risk

management.

Fostering relationshipswith management,

internal auditors, andindependent auditors.

Assessing the internal auditor’s performance.

Overseeing financialreporting anddisclosures.

2 2 2 2

1

Encouraging a tone atthe top that conveys basicvalues of ethical integrity,

legal compliance, and strongfinancial reporting and control.

Monitoring conflict ofinterest policies and

procedures.

Assessing the independent auditor’s performance.

Conducting open andcandid discussions with

the independent auditorson tone and culture.

Determining whether USNHhas an effective compliance

and ethics program.

5.00

Average Rating

5.00

5.00

5.005.00

10 0 0

1 1 10

13

5 56

43

46 66

54 4

54 4

23

Fostering relationshipswith management,

internal auditors, andindependent auditors.

Overseeing assignedportions of enterprise risk

management.

Staying up-to-date onchanges impacting the

organization.

Prioritizing the meetingagenda to focus on themost important issues.

Questioning management,internal auditors, andindependent auditors

about the quality of thecontrol environment.

Assessing whether USNHhas adequate processesand controls to prevent

and detect fraud.

Understanding how USNHpublicizes, monitors, and

enforces its writtencodes of conduct.

Determining whether USNHhas an effective compliance

and ethics program.

Challenging managementand applying skepticism.

Not Effective Minimally Effective Somewhat Effective Generally Effective Highly Effective Don't Know

USNH Board of Trustees | Audit Committee Evaluation 2022

Response Frequency

MEMBER Assessment of Committee Effectiveness | Scale: 1.00− Not Effective to 5.00− Highly Effective

N = 2

5.005.00 5.00

4.504.50

4.50

4.504.50

4.004.00

*

*

*

* One of two respondents answered this question.

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Audit Committee

Information Item

Supporting Materials Summary Sheet

University System of New Hampshire To: Audit Committee Re: USNH Audit Committee Charter (attached) – For Information, No Action Required SUPPORTING MATERIALS (attached) – SUMMARY AND SALIENT INFORMATION

The Audit Committee has the responsibility to review and assess the adequacy of its Charter on an annual basis and recommend any changes to the Board. No changes to the Audit Committee’s charter are recommended by USNH staff at this time. SUBMITTED AND APPROVED BY:

Catherine A. Provencher Chief Administrative Officer and Vice Chancellor for Financial Affairs & Treasurer

Date Prepared: June 14, 2022 For the Meeting of: June 23, 2022

-- End of Summary Sheet --

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II. Audit Committee Charter

The following responsibilities supplement the Audit Committee's charge contained in the USNH Bylaws.

In fulfilling its responsibilities, the Committee shall take appropriate actions to set an overall tone for quality financial reporting, sound business practices, and ethical behavior.

1. Ensure the Integrity of Financial Reporting:

(a) Review and approve the annual financial statements of USNH and receive and review the audit reports thereon, including those pertinent to Federal awards received by USNH as required by the U.S. Office of Management and Budget.

(b) Review the judgments of USNH management and auditors about the quality and consistency of the USNH's application of accounting principles; the reasonableness of significant judgments; and the clarity and completeness of the financial statements and related disclosure.

(c) Confirm with management and the external auditor that the annual financial statements disclose all material off-balance sheet transactions, arrangements, obligations, and relationships of USNH with unconsolidated entities or persons that may have a material current or future effect on financial condition, liquidity, or components of revenues or expenses.

(d) Review new and significant accounting pronouncements with the external auditor and understand their impact on the USNH financial statements.

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https://www.usnh.edu/

(e) Obtain a report from the external auditor annually regarding required communications under the American Institute of Certified Public Accountants' standards.

2. Oversee the External Audit Process:

(a) Recommend to the Board the appointment or retention of the external auditor for USNH, and be responsible for the compensation and oversight of the external auditor. In accordance with the Board of Trustees' External Audit Policy, the external auditor shall be engaged from among the major national public accounting firms, subject to the Board’s continuing satisfaction with the firm’s services and with re-proposals to be reviewed after each five to seven year period.

(b) Ensure rotation of the lead audit partner on the audit engagement at least every seven years, independent of the timing of the external audit firm's initial or subsequent engagements.

(c) Pre-approve all audit and non-audit services provided by the external auditors in excess of $30,000 and ensure such services do not include management functions, internal audit services, or other services prohibited by independence standards for the auditing profession, including those standards established by the U.S. Government Accountability Office. External auditor services approved by the Chairperson between Committee meetings shall be reported to the entire Committee at its next scheduled meeting.

(d) Assess the independence of the external auditor on an annual basis by reviewing the written communication from the external auditor required by professional auditing standards and discussing any relationships disclosed that may impact auditor objectivity and independence.

(e) Resolve disagreements between management and the external auditor regarding financial reporting.

3. Oversee the Internal Audit Process:

(a) Review and appraise the organizational structure, qualifications, independence, budget, and activities of the USNH internal audit department.

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(b) Review and approve the annual internal audit plan and receive interim progress reports on the plan.

(c) Review and concur with the appointment, reassignment, or termination of the Director of Internal Audit.

(d) Periodically review USNH's Internal Audit Charter for necessary changes.

(e) Receive reports of completed internal audits prior to each meeting, and at least annually receive updates on the status of management's actions in response to significant findings from prior reports.

4. Oversee Risk Management Processes:

(a) Inquire of management, the internal auditor, and the external auditor about significant financial and compliance risks or exposures to USNH, and assess the steps management has taken to mitigate such risks or exposures.

(b) Review and accept the USNH Environmental Health and Safety Council's annual report on behalf of the Board.

(c) Review areas of risk assigned to the Audit Committee by the Executive Committee for further review or other follow-up based on annual enterprise risk reports from the System’s chief executive officers.

(d) Monitor adherence to USNH conflict of interest policies and related procedures.

5. Other:

(a) Provide for the confidential, anonymous submission by employees and other USNH constituents of concerns related to questionable accounting, auditing, or business practices.

(b) Obtain reports concerning any financial fraud resulting in losses in excess of $10,000 or involving a member of senior management.

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(c) Maintain open lines of communication between the Committee and the USNH external auditor, internal auditor, and management.

(d) Review and assess the adequacy of this Charter on an annual basis and recommend any changes to the Board.

University System of New Hampshire 5 CHENELL DRIVE, SUITE 301 | CONCORD, NH 03301

Copyright © 2014 University System of New Hampshire. All Rights Reserved TTY Users: 7-1-1 or 800-735-2964 (Relay NH)

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Audit Committee

Information Item

Supporting Materials Summary Sheet

University System of New Hampshire To: Audit Committee Re: Outstanding Audit Issues – For Information, No Action Required SUPPORTING MATERIALS (attached) – SUMMARY AND SALIENT INFORMATION

The list of outstanding audit issues includes all significant open issues from past audit reports and those that were closed since the report was last distributed to the Audit Committee. It is updated semi-annually for follow-up and control monitoring purposes. Of 92 action plans currently being tracked, 10 are from internal audit reports issued since the last semi-annual update, 17 underlying risk/control issues have been reported by management as resolved, and remaining 65 are in process, much improved, on hold, and/or management has accepted the residual risk. SUBMITTED and APPROVED BY:

Catherine A. Provencher Chief Administrative Officer and Vice Chancellor for Financial Affairs and Treasurer Date Prepared: June 14, 2022 For the Meeting of: June 23, 2022

-- End of Summary Sheet --

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Jan-22 Sep-22 In Process 05/22

Dec-21 Sep-22 In Process 05/22

GSC Student Identity and Financial Verification

Enhance compliance with Title IV federal financial aid requirements

(1) Information on the Administrative Failure (AF) and Failure (F) grade difference was reviewed at the Fall Undergraduate Faculty Meeting (includes adjunct faculty) on October 19, 2021.(2) Targeted outreach to faculty teaching in high enrolled, high frequency courses will be conducted during fall term, prior to the end of term grade deadline. These courses typically have higher D/F/W/AF grade rates and often include first-time students. (3) Academic Affairs will review other institutions’ policies on attendance, participation, and AF grade definition as part of our review of academic policies that will be taking place during merger working groups. (4) Financial Aid will review current practices related to the review of HS transcripts. The federal verification rules are changing with regards to the review of high school transcripts. We will review the new guidance and adjust our practices. (5) The Financial Aid Office will enhance current protocols for selecting and documenting students for verification. (6) The Financial Aid Office will work with Academic Affairs to review course activity for the identified students to determine if academic requirements were met and adjust financial aid, as appropriate. (7) The Financial Aid Office verified the authenticity of the High School transcripts identified as potential problematic during this audit. The two students in question completed High School. (8) The Financial Aid Office already devotes much effort to the review of documents but will increase scrutiny on required documents, develop additional follow up procedures for instances of potential conflicting information, and train responsible staff. (9) The Admissions Operations Office is reviewing the possibility of adding academic purpose questions to the admissions application. (10) In response to this audit, the Admissions Operations Office created a report to search for duplicate IP addresses used to submit the admissions application. The office is developing a procedure to review IP address over the past year to identify any duplicates and will develop a policy to determine if students should be accepted. Currently, when a student or group of students presents with a red flag during admissions, they ask for additional identity verification documents.(11) The Financial Aid Office will develop formal protocols to report suspected fraud to the Department of Education Inspector General’s Office. (12) The Student Accounts Office will develop a report to search for duplicate bank account information on the student record. (13) The Financial Aid Office will explore the possibility of dividing disbursement of aid into multiple disbursement dates.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/02/22: (1) Information on AF vs. F grading was included in the agenda for the all undergraduate faculty meeting on 10/19/21. (2) Targeted outreach to faculty via email was completed during the fall semester. (3) In process (4) Verification Groups V4 and V5 no longer require high school transcripts for 22/23 year. The FAO will develop a process to identify and review HS transcripts received by the Registrar's Office to compare with HS noted on FAFSA. FAO will discuss methods used by other USNH institutions to resolve conflicting information. (5) The FAO will review options for further verification selection procedures. We may re-institute verification requirements for certain populations based on increased problematic areas. In the past we required verification items from all students outside New England. The FAO will continue to review and update protocols as needed. (6)Financial Aid discussed with Academic Dean and determined that the GSC faculty issued grades based on their interpretation of student performance. Grades are the purview of faculty. No grade change was warranted. (7) In November 2021, the Director of Student Financial Aid called the high school in question to validate and confirm that the student graduated high school. (8) The FAO will discuss methods other USNH schools use to resolve conflicting information issues. Currently the FAO does well at resolving conflicting information. We meet regularly to discuss approaches and to review documents. We will update this response after speaking with USNH FA offices. (9) Admissions added academic purpose questions on the student application in October 2021. (10) The Admissions Operations Office created a report/dashboard to identify duplicate IP addresses used in the submission of applications. Worked completed in October 2021. (11) The FAO will continue to work on developing formal protocols in conjunction with other USNH schools. (12) The Student Accounts Office submitted a report request to create a report showing duplicate bank accounts. Work to be completed by 4/30/22. (13) Due to pending merger with UNH, GSC will not significantly change the disbursement process. GSC will explore options of developing new policies and procedure related to disbursements as decisions related to the merger are finalized. Work to be completed by 9/30/22.

2 2021 GSC Student Identity and Financial Verification

Enhance student refund processing protocols

(1) The Student Accounts Office is reviewing the refund process to develop controls over the process and ensure that no one person is able to adjust addresses and disburse funds. (2) The Director of Student Financial Services will review and remove staff modify access to Banner Form GXADIRD. If access levels can not be adjusted, GSC will develop a process to review and approve student bank account changes processed by GSC. (3) The Student Accounts Office will review current workflows for the advance book fund payments to students and explore the possibility of controls over the process. (4) The Student Accounts Office will review refund process to determine potential controls over payee changes. Payee changes are needed when issuing refunds to 3rd party or to parents in the case of PLUS loans.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/02/2022: These actions are in process and will be topics for discussion as the merger between GSC and UNH-M moves forward.

Originally Reported Audit Risk/Control Issue Action Plan & Responsible Party StatusOriginal

Target DateEntity

OUTSTANDING AUDIT ISSUES MONITORING MATRIX as of 6/08/2022

# Revised Target Date

1 2021

Page 1 of 29

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of 29


Target DateEntity# Revised Target Date

Jan-22 Jul-22 In Process 05/22

Jan-22 Mar-22 In Process 05/22

Jan-22 Sep-22 In Process 05/22

Dec -17 Apr-23 In Process 05/22

Dec-20 Apr-22 Resolved 06/22

Enhance GSC student account policies and procedures

(1) The Student Accounts Office will conduct a review to determine areas where Red Flags may occur. (2) The Student Accounts Office will review the USNH Identity Theft Prevention Program and update GSC policies. (3) The Student Accounts Office will develop training for staff working in areas where Red Flag Rules apply.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/02/22: The Student Accounts Office will continue to review areas where Red Flags may occur. We have had discussions of Red Flag areas at the USNH GLBA meetings. We are reviewing the UNSH Identity Theft Prevention Program.


Enhance WebRock account setup and security protocols

(1) Multi-factor authentication is being considered for WebRock. (2) The WebRock set up process will be reviewed to determine the available time available for a student to set up the account and if identity can be validated during the setup.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/20/22: (1) MFA for GSC Webrock was implemented on 4/12/22. (2) The evaluation of account setup link active time period and identity verification requirements is in proces with USNH Cybersecurity and IAM. Work to be completed by September 30, 2022.


Enhance protocols for sensitive student data

(1) The Academic Advising Office developed a process protocol to identify students when on the phone. The process includes asking students to verify non-directory information contained in the student record. The process is documented in an Standard Operating Procedure (SOP). The process was shared and adopted by the Admissions office in October 2021. This process will be shared with other offices that interact with students. Work to be completed by November 30, 2021.(2) In response to this audit, the Academic Advising Office developed a procedure to redact personal information found in student correspondence saved in Salesforce. Work completed on October 13, 2021. The Financial Aid Office is reviewing the possibility of redacting information in documents submitted and stored in Xtender. The redaction of sensitive information in Xtender will be very difficult. That information may be needed to link the student to the document and information can be found in a number of places within a document, particularly if the document is lengthy. There would be no standard way to review each document and perform the redaction. The Financial Aid Office will review Xtender access by other departments and evaluate other individuals access for appropriateness. The Financial Aid Office will review options to purge old data from Xtender. Work to be completed by January 31, 2022.

MGT. EXPLANATION & RESOLUTION PLAN @ 6/1/22: (1) The SOP developed by the Academic Advising Office was shared with college supervisors at an Operations Group Meeting. The policy was updated and adopted by Financial Aid and Student Accounts in January 2022. (2) The Financial Aid Director will restrict access for selected documents in Xtender to FA staff only and restrict access to other documents to staff who have a job related need to review. The Financial Director will discuss record retention policies as part of the proposed merger. Revised completion date is August 31, 2022.


7 2019 KSC Sponsored Projects Review

Enhance controls to comply with Uniform Guidance and grant

terms and conditions

(1) Updated research policies and procedures will be developed and implemented by December 31, 2020 and incorporated into KSC research training initiatives. OSPR will update the existing grants administration roles and responsibilities matrix by December 31, 2020.(2)The Keene State College Grants Policies and Procedures Manual will be reviewed and will be updated to reflect current processes and updated policies and procedures. OSPR training will be reflective of policies and procedures outlined in the manual. (3) Starting in October 2019, OSPR will conduct a kick-off meeting at the beginning of the grant with the PI. PIs will be trained on research policies, procedures and compliance requirements. A grants management checklist and policy acknowledgement page will be developed for use at this kick-off meeting starting in June 2020. (4) OSPR will remove unallowable costs. (5) OSPR will develop a PI reporting package for PI's.(6) OSPR will develop protocols for the monitoring and tracking of cost share.(7) Management will develop grant expense allowability and allocability guidance.(8) Effective in Nov 2019, management instructed staff on documentation required to support expense allocability and business purpose, OSPR started to document review and approval of invoices and financial reports, and PI approval is now required prior to the processing of grant labor distribution changes.

MGT. EXPLANATION & RESOLUTION PLAN @ 11/15/2021: (1)-(3), (5)-(8) Resolved: Effective April 2021, UNH Sponsored Programs Administration is providing research administration services to KSC. UNH policies and procedures have been adopted and implemented across all USNH campuses that aligns with the new operating structure. UNH Research is working on updating polices and proceures to reflect all campuses and provide links on individual campus websites. (4) Resolved: All unallowable costs identified have been removed from the grants.

6

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) - (2) In Process. The overall ETS DRBC Plan has been approved and was tested by a table top exercise in March 2022. The next table top exercise ll will be conducted in the fall of 2022 including a review of the service line leaders subplan presentations. A full test of the KSC backup will not be conducted until 2023 at the earliest. The due date for the management action plan was extended to April 30, 2023. (3) Resolved.

2017 KSC Data Center

Move towards full recovery testing of KSC key services

(1) Review technical infrastructure barriers and execute plan to remove barriers and enable full restore off-site at UNH(2) Conduct annual DRP exercises for individual Tier 1 services and tabletop exercises for selected other tiers of service to test DRP processes and procedures(3) Enhance current testing verification from business units that will provide details of acceptance testing and verify successful recovery

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Jun-20 Sep-22 In Process 05/22

Jun-21 Apr-22 Resolved 05/22

Jun-22 Jul-22 In Process 05/22

Nov-20 Jun-22 In Process 05/22

Sponsored Projects Review

Improve grant closeout controls and procedures

MGT. EXPLANATION & RESOLUTION PLAN @ 05/05/22: (1) Resolved. Effective April 2021, UNH Sponsored Programs Administration is providing research administration services to KSC. All KSC grants are going through the UNH SPA closeout workflow. (2) Resolved. With the revised structure, UNH SPA is now handling invoicing and financial reporting and applying UNH review/approval protocols to KSC grants. (3) In Process: KSC is working with UNH to resolve unbilled activity on grants that have ended and using the UNH workflow system to close and deactivate the grant funds. Due to competing priorities, additional time is needed to close out old grants and process related adjustments.

(1) Grant closeout policies and procedures will be developed and implemented by June 30, 2020. OSPR will review and streamline the current grant closeout process using a modified current practice or through the implementation of Banner Workflow. (2) Effective October 2019, OSPR has started to document the review and approval of invoices and financial reports.(3) Management will review unbilled activity on grants that have ended and determine the appropriate action and submit the list of active expired grants to FAST for inactivation by February 28, 2020. Starting in February 2020, on a monthly basis, OSPR will use WebI reports to review unbilled grant expenditures, refunds due sponsors, and fund aging.

The Fund Steward Assistant is tasked to audit a sample of gift expenditures recorded by the gift funds. Currently, the focus has been on scholarships and awards annually, with a plan of expanding to the other gift funds. Going forward, we will review a sample of gift expenditures that are recorded by the gift fund on a quarterly basis, to ensure that the transactions are in compliance with donor restrictions. The first review will be performed by November 30, 2020.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: In Process: All scholarship audits have been completed. In addtion, the gift fund audits will be completed before the end of the fiscal year. As of April 2022, of the 33 gift funds selected for audit, 25 audits have been completed.

(1) Each new fund Banner request will be reviewed by another Advancement Services staff member before submission to the campus business office. This was been put in place on July 1, 2020.(2) We will review all Banner Finance funds for appropriateness. We will review 1/3 of all active funds annually with three review goals: top 1/3 of funds by December 31, 2020, including higher dollar/higher risk funds; next 1/3 of funds by August 31, 2021; last 1/3 of funds by June 30, 2022.(3) Beginning FY21 if there is an addendum to an MOU, the language will include "Any money in the restricted gift fund will be awarded using the new restrictions". Banner Finance fund text will be updated with the change and effective date of said change. Copies of the executed addendum to the MOU (if it is a minor change) will be shared with all appropriate campus partners and USNH. If the change is deemed significant to effect coding, or overall intention, a new fund will be created. This was put in place on July 1, 2020.(4) The current process of a campus department notifying Advancement, and Advancement staff initiating any changes to existing gift restrictions will be documented. This will be completed by October 31, 2020.Responsible Party is KSC Director of Advancement Services & Director of Development

8 2019 KSC

9 2020 KSC Advancement Operations

Enhance the current chart of accounts


Enhance gift restriction tracking

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) Resolved. (2) Resolved. We have reviewed approximately 84% of all Banner Funds for appropriateness and any identified changes have been submitted to be updated. The review will be completed by July 1, 2022. (3) Resolved (4) Resolved. The action was completed on 4/6/2021

(1) We will review all advancement related Banner Finance funds for appropriateness to ensure that gifts are recorded in the correct funds. We will set up a meeting with USNH Finance and the KSC Business Office to review current practice of establishing activity codes instead of new gift funds.(2) We will set up a meeting with USNH Finance and the KSC Business Office to review current fund creation coding and procedures by August 31, 2020. We will also review all fund designated funds (5D) for correct coding. This will be completed by December 31, 2020. Any funds identified will be corrected by June 30, 2021.(3) As stated in (1) & (2) the funds will be reviewed and any adjustments will be made by December 31, 2020. (4) We will review the Raiser's Edge to Banner Finance mapping annually, by comparing the Raiser's Edge fund GL report to Banner Finance WebI FBAL 1050 report. The first review will be completed by December 31, 2020. Responsible Party is KSC Director of Advancement Services & Fund Stewardship Assistant

MGT. EXPLANATION & RESOLUTION PLAN @ 05/16/2022: (1) Resolved. The meeting with USNH Finance and the KSC Business Office was held on August 17, 2020. All advancement related Banner Finance funds have been reviewed for appropriateness and any issues were addressed. Specifically, activity codes are no longer used and any older gift funds which are no longer used were closed. (2) Resolved. All 5D funds were identified and corrections were processed. (3) Resolved. (4) Resolved.


Enhance donor compliance procedures

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Jun-21 Jul-22 In Process 05/22


Jun-21 Sep-22 Resolved 06/22

Mar-22 Sep-22 In Process 05/22

15 2021 KSC Admission Data Security

Enhance security protocols to access key applications

(1) We are currently consulting with the KSC/CRM technical manager and the USNH CRM team to implement multi-factor authentication (MFA) for Salesforce TargetX. PSU is going to be first school to enable this and they have been working with the security team to move this to production. Once they have completed their implementation, we will copy their plan. This will be completed by December 31, 2021.(2) As for EAB, two-factor authentication is on the road map and a priority for EAB, but unfortunately it might not be ready by the beginning of 2022 for the MyAnalytics portal. EAB is committed to this important enhancement and will update us as we get closer to 2022. This will be completed by March 31, 2022.(3) The Director of Admissions will work with the USNH Chief Information Security Officer to implement MFA for Ellucian Colleague. This will be completed by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) Resolved. Two-factor authentication has been implemented for the KSC/CRM platform Salesforce TargetX. (2) In Process: KSC is currently working with the vendor EAB to implement two-factor authentication for EAB. An updated completion date of June 30, 2022 has been requested. (3) In Process: USNH IT is currently working on the implementation of MFA on Ellucian Colleague. An updated completion date of September 31, 2022 has been requested.

(1) A formal policy, including protocols and guidelines, will be created by the Financial Aid Office (FAO) addressing recommendations. We will ensure that security protocols and guidelines are reviewed by the USNH Information Security Officer prior to distribution. We have already begun to establish new procedures when emailing staff or other offices regarding a student. In addition, we have begun to review our reports to determine what data can be hidden from a report if it is not needed for the job being done.All students are asked to show their KSC ID before any information is given to them. If the student/parent is calling, we do review the FERPA spreadsheet to ensure we have permission to speak with the parent. We will develop a formal policy, including protocols and procedures to verify the student’s identity before accessing the student’s account. (2) Regarding the fax machine, KSC has recently been using Dynamic Forms for the submission of Financial Aid (FA) forms. We will investigate the feasibility of and/or purchasing a dedicated, non-network fax machine for use in faxing and receiving faxed documents with sensitive data. Alternatively, the office may end fax use (both sending and receiving).

The Vice President of Enrollment and Student Engagement with work with USNH Information Technology to review our security protocols and determine further action by June 30, 2021.

12 2020 KSC Financial Aid Data Security

Enhance protocols for sensitive data handling

KSC Financial Aid Data Security

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) In Process: A formal policy, including protocols and guidelines were created and they are awaiting supervisor approval. An updated completion date of July 31, 2022 has been requested. (2) Resolved: KSC Management determined that faxes will no longer be accepted by KSC Financial Aid.

Enhance protection of data on end user devices

The Director of Financial Aid and Scholarships will work with our IT department to ensure all laptops are encrypted. The FAO currently does not use mobile devices containing any sensitive data. The FAO will submit a ticket to IT to request a third-party software be run on a weekly basis and for assistance in creating an established protocol for removal of any malware. Students will be asked to provide their own laptop to complete the FAFSA until a standalone CPU can be installed for this purpose. This will be completed by June 30, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: In process: All KSC Financial Aid laptops were encrypted. USNH IT is currently working to implement scanning for unprotectied data with the Spirion Solution at KSC. KSC management has substantially addressed the risk. Going forward, the risk is being classfied as medium risk, but will be continued to be followed up by USNH Internal Audit until the risk is fully addressed.

14 2020

13 2020 KSC Financial Aid Data Security


MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: In Process: USNH IT is currently working on the implementation of MFA on Ellucian Colleague. An updated completion date of September 31, 2022 has been requested.

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Jun-22 Jun-22 In Process 05/22

Dec-21 Dec-21 Resolved 06/22


Admission Data Security

Enhance protection of data on end user devices

(1) The Director of Admissions will work with USNH Chief Information Security Officer to ensure all laptops are encrypted. We will submit a ticket to IT to request a third-party software be run on a weekly basis and for assistance in creating an established protocol for removal of any malware. This will be completed by September 30, 2021.(2) In addition, the USNH Chief Information Security Officer will ensure a process is developed to ensure all computers are encrypted before they are issued to departments. This will be completed by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) In Process: All KSC Admission laptops were encrypted. USNH IT is currently working to implement scanning for unprotectied data with the Spirion Solution at KSC. KSC management has substantially addressed the risk. Going forward, the risk is being classfied as medium risk, but will be continued to be followed up by USNH Internal Audit until the risk is addressed. (2) Resolved. A process has been developed to ensure that all computers are encrypted before they are issued to departments.



Enhance data security over payment card data

(1) We have reached out to the USNH Director of Treasury to replace the current terminal. We will also review of all current paper applications to delete credit card information and SSN. The project was submitted to KSC Marketing for the re-design. This will be completed by September 30, 2021. (2) In addition, we will investigate a way for re-admit and transfer students to pay the application fee and/or deposit via an online portal. This will be completed by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) Resolved: All credit card terminals have been replaced by PCI compliant terminals. Also, all current paper applications, the credit card information and SSN field was deleted. (2) Resolved: Transfer students are now able to pay their application fee and/or deposit fee via the online portal. For re-admit students, the application fee was waived and the deposit fee can be paid via the online portal.

Enhance vendor security review protocols

(1) As contracts expire, we will confirm with the USNH Chief Information Security Officer that vendors are meeting all USNH requirements to protect sensitive student data. In addition, we will contact USNH Procurement services to initiate discussions with vendors to sign an updated contract as the contracts expire. We will confirm that all appropriate data security language is included in contracts as they are updated and renewed. This will be completed by June 30, 2022.(2) A project request was submitted to the CRM technical manager to develop a business continuity plan. Check in will happen on November 1, 2021, on the progress of this project. This will be completed by June 30, 2022.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) -(2) In Process: The due date for the management action plan is June 30, 2022.

18 2021 KSC



(1) We are currently accepting high school transcripts and other documents with sensitive data via email. We already have a system in place for high school counselors to submit these transcripts securely. We will reinforce the usage of this system. In addition, we will be developing an alternate way for those counselors that are challenged by technology to send transcripts on behalf of the applicant in a safe manner. This process will be in place in time for the next application cycle (September 30, 2021).(2) A formal policy, including protocols and guidelines, will be created by the Admissions Office addressing all of the above recommendations by December 31, 2021. We will ensure that security protocols and guidelines are reviewed by the USNH Information Security Officer prior to distribution. (3) We will review the USNH Cybersecurity Policy USY VIII.C.4 to ensure compliance with this policy (September 30, 2021)(4) We will be developing a retention policy for paper documents and documents stored within the system, with the CRM team and consult USNH legal team. This will be completed by October 31, 2021.(5) We will investigate the feasibility of and/or purchasing a dedicated, non-network fax machine for use in faxing and receiving faxed documents with sensitive data. Alternatively, the office may end fax use (both sending and receiving). This will be completed by September 30, 2021.(6) We will reinforce the existing policy to only use the dedicated scanning workstation to scan sensitive data.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: (1) Resolved for the January 2022 Audit Committee Meeting. (2) In Process: We are working on drafting a formal policy, including prototols and guidelines regarding data security protocols (3) In Process: This will be completed during the drafting of the formal policy. A new due date of September 30, 2022 s requested. An update will be providded during the January 2023 Audit Committee meeting. (4) - (6) Resolved for the January 2022 Audit Committee Meeting.

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Aug-19 Dec-21 In Process 06/22


Dec-21 Jul-22 In Process 05/22

Dec-21 Dec-21 In Process 05/22

22 2020 PSU Student Billing Audit

Enhance the review and approval of billing rules

SFS had already self-identified some of these issues noted above prior to this Internal Audit report as evidenced through official performance enhancement plans in place through HR. As the billing rules for the Summer 2021 term were being built congruent with this audit, SFS has already begun the process to assist with the development and creation of formal protocols for segregation of duties between rule changes, testing of rules changes, and tuition billing. These new processes now consist of the billing manager and student accounts receivable team complete testing new billing rules before implementation. The final step will be the Director approving the billing rules once testing is complete. In regard to manual adjustments, a list will be created and reviewed at least quarterly by the Director of SFS, beginning no later than June 30, 2021. Although the policies and processes are being developed now, SFS plans to have a complete process narrative and enhanced policy in place by December 31, 2021. In addition, desk procedures over rule changes and billing adjustments will be created and SFS staff will be trained on these desk procedures. This will be completed by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/27/2022: In Process: PSU management developed and implemented procedure to reviewed and signed off all rules at three different levels prior to them being placed into production. In addition, there are now written procedures in the term setup instructions. We are in the process to implement procedures regarding the review of manual adjustments. Going forward, the PSU Billing Specialists will be responsible for reviewing all accounts and recommend manual adjustments to the PSU Billing Manager. After review the billing manager makes manual adjustments and notates RHACOMM that adjustment has been made. Lastly, all manual transactions will be reviewed for accuracy during the end-of-day cashiering by the Billing Specialist. We are currently in the process of formalizing this review. Through the review process done by the Billing Manager and Billing Specialists during the rule set-up, if any changes need to be made to the rules, they are made in test before the move to production. We noted that the pre-billing module in Banner is incompatible with the Cluster Model of billing used at PSU. We have developed a report to identify any billing variances. The report is run and reviewed after each billing cycle. Lastly, we have updated the workflow procedures to outline staff roles in rule changes and student billing assessment. The due date was extended to July 30, 2022.

23 2020 PSU Student Billing Audit

Enhance policies and procedures for billing course load changes

SFS agrees to enhance formal policies and procedures regarding the authorization of refunds. SFS will review current add/drop and withdrawal policies with the Registrar’s Office and enhancement recommendations will be made to PSU Senior Management. Any of those approved by PSU Senior Management will be incorporated into current policies/procedures. SFS will work with the relevant offices (i.e., Registrar’s Office, Housing/Dining Office, etc.) to establish a more formal communication plan regarding billing-related changes to reduce risk and close gaps. The necessary enhancements to policies and procedures will be implemented by December 31, 2021. Going forward, protocols will be created to ensure all stakeholders are informed of any upcoming student accounts related policy changes to provide input and discuss implications. This will be implemented by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/27/2022: In Process. Going forward, all billing refund rules are established prior to the start of each term and approved by SFS management based on University Policy. The refund authorization is set up to run automatically. The PSU Billing Specialists reviews individual accounts for accuracy during end-of-day cashiering. PSU SFS is working more closely with the Registrar's Office to understand each office's specific role in the withdrawal process. Any identified changes will be made in the course catalog and PSU website as needed. Reviews have been completed by SFS for consistency between the course catalog and PSU documented policy on its website. We are currently documenting the review process. The due date was extended to September 30, 2022.

Oracle Database Audit

20 2019 PSU Sponsored Projects

21 PSU2019

(1) PSU will perform a detailed review of projects that have ended and inactivate and closeout these grants and funds in Banner by June 30, 2019.(2) Going forward, PSU will incorporate the setup and reivew of grant demographic information as part of defined roles and responsibilities and updated policies and procedures by August 31, 2019.

Security hardening and configuration needs improvement

Inadequate controls over maintenance of grants in Banner

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/22: (1) In Process: The review, inactivation, and closeout of ended projects is still ongoing with UNH SPA. This has been delayed due to efforts related to transition and integration of campus sponsored programs into UNH SPA. (2) The roles and responsibilities matrix has been completed, which denotes the responsibility for the entry, review, and approval of grant fund setup in Banner.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/25/2022: (1) Resolved (2) In process. PSU Oracle Databases are being migrated to a network where the Rubrik backup system is available. Once complete, backups will be encrypted using standard processes also employed by the UNH Banner and related ERP environments. The Due date was extended to September 30, 2022. An update will be providded during the January 2023 Audit Committee meeting. (3) Resolved (4) In process. OEM has been deployed and is currently managing PSU production databases. The PSU test databases are being moved to a network where both Rubruk and OEM are available. Phase one of that move to the new network has been completed, and validation tests are being performed now. Once those completed, system integration into both Rubrik and OEM will be done to complete this audit finding. Due date was extended to September 30, 2022. (5) Resolved

(1) Password Profiles will be reviewed and will be aligned with the PSU Password policy guidelines. (2) Database encryption is being researched for both at rest and in flight and will be piloted by end of June 2020. UNH will also be contacted to identify the methodology employed by them. (3) Oracle Masking for sensitive data is completed. (4) PSU will work with USNH colleagues to determine and develop a database logging and operating system process/standard including a formal review of logs. (5) We will work with the PSU ITS CSO to formalize a security configuration hardening standard for the database. We will also remediate the listener settings and SQL 92 and sessions per user providing database performance is not impacted. Responsible Party: PSU Director Management Information System

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Sep-22 Sep-22 In Process 05/22

(1) We will review, update, and communicate to all PSU Financial Aid staff our current security protocols and guidelines to ensure all different aspects of the handling of sensitive data is included in our Data Security Reminder document, including the proper handling of sensitive information in the office, information that should be received via fax and email, what type of sensitive information should be uploaded to ApplicationXtender and OneDrive folders, the protocols for scanning this sensitive information, the redaction of sensitive information (where possible). In addition, we will set up a meeting with the USNH CISO and the USNH Director of IT Governance, Risk and Compliance to discuss the use of OneDrive to upload sensitive student information to ensure the folder is appropriately protected and the most recent security protocols and guidelines. This will be completed by September 30, 2022 by the PSU Director of Student Financial Services. (2) We will reinforce with Financial Aid staff the existing verification procedures to ensure sensitive student related information is only provided to a person if a student completed the required permission form. This will be completed by June 30, 2022 by the PSU Director of Student Financial Services. (3) We will propose and implement a schedule when documents that are stored on ApplicationXtender, shared drives, OneDrive, and Dynamic Forms can be securely purged. In addition, we will identify a PSU Financial Aid staff that will be responsible to purge this sensitive information based on the schedule. This will be completed by September 30, 2022 by the PSU Director of Student Financial Services. (4) We will investigate the possibility of deleting fax machine memory on a daily basis to reduce the exposure and will reach out to ET&S Cybersecurity to develop an interim solution. We will explore the possibility of getting a new device to replace the existing fax machine. We will complete this by September 30, 2022 by the PSU Director of Student Financial Services.

MGT. EXPLANATION & RESOLUTION PLAN @5/19/2022: NEW

24 2020 PSU

2020 PSU Student Billing Audit

Enhance procedures surrounding collectability of outstanding

student debt

Student Financial Services will refine the write-off policy (600-046) prior to July 15, 2021 to ensure it more clearly reflects that the 120 days write-off rule applies only to inactive student accounts and not the active student actions to avoid misunderstandings. Student Financial Services will broaden existing policies and procedure around outstanding balances and financial holds by December 31, 2021. It’s important to note that the FY20 write off amount is higher than usual due in part to the COVID-19 pandemic which caused a myriad of financial hardships for students/parents throughout the year. SFS already contacts students weekly leading up to term start but will document this more clearly going forward. This will be implemented by December 31, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/27/2022: Resolved: A procedure has been put in place to run monthly reports that qualifies all inactive students accounts that are 120 days old. These students are reviewed by a Billing Specialist and sent to the Billing Manager for approval. Once approved, the Billing Specialists places a collections hold on the account and the balance is written off by the Financial Support Specialist. In addition, pa rocedure has been put in place to communicate via email, voicemail, text, and social media posts informing students about their outstanding balance on a monthly basis. Students are advised if a financial plan is not established immediately, they are dropped for non-payment.

Enhance protocols related to mandatory and course related

fees

(1) The Finance Division, in conjunction with the Registrar’s office, will establish/enhance policies and procedures regarding the set up and use of course related fees by December 31, 2021. Through the implementation of the UShop tool, the majority of expenses charged against course fee revenues is evaluated at the time of purchase. For those items, such as reimbursements, that are not processed through the purchasing tool, the Finance Division will establish a periodic review process to ensure the appropriateness of expenses charged against course fee revenues beginning July 1, 2021. (2) PSU Finance will create a formal policy on how student fees can be used. This will be implemented by December 31, 2021. Procedures on how to access/spend the dollars will be governed by USNH purchasing and disbursement policies and procedures. Through the UShop tool, the PSU Finance Office has greater insight into related expenditures that are occurring and by virtue of their approval of the requisition is validating the appropriateness of the expense. As the new FAR travel and expense process is being constructed, PSU is advocating to have Campus Finance Offices inserted the Banner Finance approval process for such payments to employ the same allowability review that occurs for transaction processed through the UShop tool.(3) Mandatory auxiliary fees support auxiliary activity, and USNH elected to classify these revenues in alignment with the activity they support. USNH Financial Services will evaluate the existing practice and as part of the policy updates underway to support the Financial Administrative Restructure project and document its justification for the classification by June 30, 2022. The language in MD&A also will be clarified to fully disclose the categories of auxiliary activities for the year ending June 30, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/27/2022: (1) In process: Due to staff turnover at PSU Finance, this has not been started. Once a new PSU Finance Division Director is hired, we will work on this management action plan. Due date was extended to September 30, 2022. An update will be providded during the January 2023 Audit Committee meeting (2) In process: Due to staff turnover at PSU Finance, this has not been started. Once a new PSU Finance Division Director is hired, we will work on this management action plan. Due date was extended to September 30, 2022. An update will be providded during the January 2023 Audit Committee meeting (3) In Process: The language in the MD&A on the 2021 audited Financial Statements has been updated to fully disclose the categories of auxiliary activities. The documentation regarding the classification is now part of a bigger project to define all fees charged to students. This is being completed as part of the chart of account framework that is currently in process. Due date was extended to December 30, 2022. An update will be providded during the January 2023 Audit Committee meeting

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Student Billing Audit

26 2022 PSU Financial Aid Data Security Review

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Jun-17 Dec-22 In Process 05/22

Sep-17 Dec-22 In Process 05/22

Dec-18 Aug-22 Resolved 05/22

Apr-19 Dec-22 In Process 5/22



ET&S Cybersecurity IAM team will work directly with the application teams for Ellucian Banner Student, MyPlymouth and Dynamic Forms to assess, prioritize and implement multifactor authentication on these systems. The expected completion date is Q3 2022 prior to students returning for Fall Semester. USNH Chief Information Security Officer



We will contact USNH Procurement, PSU Facilities and USNH Director of IT Governance, Risk, and Compliance to initiate a discussion with Shred-It USA regarding an updated contract and to conduct a security review of the vendor prior to the signing of the updated contract. This will be completed by September 30, 2022. PSU Director of Student Financial Services


Enhance guidance, tracking and monitoring of non-PHS FCOIR disclosures and requirements

(1) UNH RIS will incorporate flowcharts into FCOIR guidance to aid researchers in identification of FCOIR that are required to be disclosed. (2) UNH RIS will use the InfoEd COI module to develop, track, monitor, manage and report on PHS and non-PHS disclosures and management plans. (3) UNH RIS will update financial conflicts of interest in research policies to mandate annual disclosures by all researchers certifying existence or non-existence of significant financial interest.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/27/22: (1) and (2) Resolved for June 2021 Audit Committee meeting. (3) A USNH working group has been formed to implement annual and real-time COI disclosures through Cayuse; policies and procedures will be updated accordingly. The working group is obtaining necessary approvals from various constituents to roll out the Annual Disclosure Form to the USNH campuses. The annual disclosure process is ready to launch pending USNH Legal approval.

Enhance tracking and monitoring of PHS-funded projects, disclosure reporting and

researcher training

(1) Implementation of InfoEd Conflict of Interest module(2) Electronic processing of proposals in InfoEd (3) UNH RIS will update written internal procedures to confirm the process for complying with federal FCOIR disclosure reporting requirements

MGT. EXPLANATION & RESOLUTION PLAN @ 5/27/22: (1) Resolved. (2) Cayuse proposal submission module with Cayuse COI integrated into the routing/review process has been launched. (3) Written internal procedures are in process, as all SOPs will be updated to reflect process in Cayuse; revised planned completion is August 2022.

Not all servers outside of the two data centers are scanned for

vulnerabilities

Enhanced vulnerability scanning program shall include: server OS security hardening, server pre and post production security audit (conducted by UNH-ISS), server vulnerability patching, and server vulnerability scanning. - CIO

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: In Process: USNH Cybersecurity has purchasd a product called Tenable/Nessus Cyber Security (a vulnerability scanner software), the Burp Suite (a web application scanner) and Spotlight (a vulnerability enumeration tool that gives hostnames and user info) that uses the USNH Crowdstrike agends deployed on over 9,000 endpoint devices. This combination of tools allows the USNH Cyber Ops team to have a much better picture of vulnerabilities wihtin USNH. The scan is performed and reported on each week and the dashboard showing any vultnerabilities are looked at almost daily. We are currently working on identifying and installing Crowdstrike on USNH endpoint devices. The due date was extended to December 31, 2022.

Addressing this issue shall entail evaluating and implementing where feasible a centralized security log aggregation database. In cases where automated centralized logging may not be feasible, a mechanism to facilitate centralized ad-hoc reporting shall be explored and implemented. - CIO

No comprehensive information security log is maintained

29 2017 UNH

2017 UNH


Information Technology Incident Response

32 2017

UNH Financial Conflict of Interest in Research

Information Technology Incident Response30

MGT. EXPLANATION & RESOLUTION PLAN @ 05/19/2022: In Process: USNH entered into an incident response contract with Crowdstrike in December 2021. Under this agreement, Crowdstrike response to incidents regarding endpoints with their agents all over a certain threshold. USNH Cyber Ops investigates lower level incidents. All logs are maintained within the Crowdstrike system. Incidents that do not involve en endpoint device such as social engineering, phishing, and smishing are recorded on a standard incident response from and stored in the Cyber OPS teams folder. All logs are maintained in a centralized loggin system called splunk. We continue to centralize the loggin system and enhance our process surounding the review of logs. The due date was extended to December 31, 2022.

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UNH Financial Conflict of Interest in Research

2017

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Nov-19 Sep-22 In Process 05/22

MGT. EXPLANATION & RESOLUTION PLAN @ 05/26/2022: (1) - (3) In Process. Work is ongoing for a centralized Linux system management. USNH IT has kicked off the final project phase of the effort, which will pull together the VMWare products installed over the past 6 months into a cohesive software defined Linux and Windows provisioning, configuration, and life cycle management system. This will include server level access and authorization. The due date was extended for the management action plan to September 30, 2022. (4) In Process: Devolutions Password Vault has been identified and the license renewed for FY23 - FY25 as the local account management tool. Implementation is in progress now. The due date was extended for the management action plan to September 30, 2022.

Access Management

(1) The standard operating procedures for the processes mentioned will be modified to include provisioning and deprovisioning responsibilities, approval requirement for IT staff, time period for removing disabled accounts and will be completed by October 31, 2019(2) The system administrators have been instructed to follow this process going forward. Completed by October 31, 2019(3) A periodic review will be performed semi-annually using a risk-based approach and sampling. This review will include all account types, password changes, login shells etc., and will be completed by June 30, 2020. The results of the review will be filed in our audit directory. (4) The superuser password vault was segregated on August 31, 2019 and system administrators are aware of the requirement to change these passwords regulary.

f f f ff

2019 UNH Linux Audit

Linux Audit

34

Security Configuration and Hardening

33 2019 UNH

Password parameters will be remediated by December 31, 2019, which will enforce password changes and the adoption of the most up to date encryption. While waiting for an approved standard for Information Technology, the SADA team has proactively analyzed and implemented CIS benchmark controls on newer servers in a manner that improves security without compromising performance or usability. It is important to remember that the CIS Benchmarks are best practice guidelines, not mandatory standards. In some cases, we determine that implementing certain Benchmarks would increase risk, without measurable improvement to security. For example, TCP Wrappers, in particular can be exploided to cause Denial-of-Service (DOS) attacks on servers where implemented. It's also an Application Layer service that is more likely to have security flws that could be exploited than a kernel-based firewall such as NetFilter or Firewalled. We believe our implementation of host-based firewall rules provides superior protection to the servers, without increasing the risk of DOS attacks. Responsible party for this action is the UNH Senior Information Technology Manager and the UNH Information Security Officer

USNH Internal Audit response: TCP wrappers (a host-based network access control list system) should not be considered a complete replacement for a properly configured firewall and other security mechanisms. TCP wrappers are used to enhance Linux server’s security, when properly used, these reduce the risk of Denial-of-Service attacks on Linux servers. We recommend that TCP wrappers should be

MGT. EXPLANATION & RESOLUTION PLAN @ 05/26/2022: In Process. Work is ongoing for a centralized Linux system management. USNH IT has kicked off the final project phase of the effort, which will pull together the VMWare products installed over the past 6 months into a cohesive software defined Linux and Windows provisioning, configuration, and life cycle management system. This will include server level access and authorization. The due date was extended for the management action plan to September 30, 2022.

35 2019 UNH Linux Audit

Unauthorized Software Protection

AIDE is currently used to notify system administrators of changed/new files through an e-mail message sent to the primary administrator. Standard operating procedures will be updated to reflect the process that all notifications should be examined and filed by November 1, 2019.

Responsible party for this action is the UNH Senior Information Technology Manager and the UNH Information Security Officer

MGT. EXPLANATION & RESOLUTION PLAN @ 05/26/2022: In Process. Work is ongoing for a centralized Linux system management. USNH IT has kicked off the final project phase of the effort, which will pull together the VMWare products installed over the past 6 months into a cohesive software defined Linux and Windows provisioning, configuration, and life cycle management system. This will include server level access and authorization. The due date was extended for the management action plan to September 30, 2022.

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2019

36 2019 UNH

38 2019 UNH Network Security Audit

(1) Due to current staffing levels, technical limits for applications and scheduling downtime, we patch every two weeks. Also, the SADA team is part of a department wide Tiger Team, led by ISS, that deals with immediate security situations. We help determine the severity of the issue and implement controls, patches, fixes, etc., as the team directs.(2) Inconsistent results with patch levels was due to the implementation of our automated Linux patching project. The first phase of the project automated patching on all servers every 30 days in the first two weeks of the month. We added a second phase to the project that scheduled patching for the second two weeks. We gathered audit data in the middle of this project, so some results are due to servers not yet scheduled for the second phase of the project. Some results may be due to some servers not being patched regularly. The completion of our Linux patching project now ensures all servers are patched twice monthly.(3) Testing approvals are required and acquired for all our changes. Approvals are not stored in one location but will be by December 31, 2019. The change management team in IT should be looked to for a standard approval process that documents approvals in the ticketing system.(4) Ensuring a set of patches is pushed to dev/test servers first, followed by production is our desired behavior. Due to recent changes to the satellite server we cannot “freeze” a set of patches, which was the earlier behavior of the satellite server. We have written a “freeze” script to ensure we are only applying tested patches. Least privilege access will be setup for our templates by October 31, 2019. (5) USNH Cybersecurity and Networking will ensure that security hardening applied complies with current security requirements.

Security Program Governance and Oversight

37

Linux Audit

Change and Patch Management

UNH Linux Audit

MGT. EXPLANATION & RESOLUTION PLAN @ 5/26/2022: (1) In Process. Patch management will be performed using Salt as a configuration management tool, as well as vRealize Life Cycle Manager. The installation and configuration of these tools is in progress now. The due date was extended for the management action plan to September 30, 2022. (2) Resolved (3) In Process. Work is ongoing for a centralized Linux system management. USNH IT has kicked off the final project phase of the effort, which will pull together the VMWare products installed over the past 6 months into a cohesive software defined Linux and Windows provisioning, configuration, and life cycle management system. This will include server level access and authorization. The due date was extended for the management action plan to September 30, 2022. (4) Resolved (5) In Process: Security hardening review of configuration and installed package versions will be available via SaltStack for review and analysis of Linux based systems. The due date was extended for the management action plan to September 30, 2022.

Logging and Monitoring

The logging has been enabled for the 1 of 5 servers identified in the audit on August 31, 2019. Logs are uploaded to Log Insight in real time. We will keep logs for 90 days and ISS will review a sampling of critical application logs, monthly. This work will be done by December 31, 2019.Responsible party for this action is the UNH Senior Information Technology Manager and the UNH Information Security Officer

USNH Internal Audit response to Management action plan:We recommend that management liaise with ISS and the USNH CIO to determine the appropriate retention period and related log review to appropriately diagnose potential security incidents.

MGT. EXPLANATION & RESOLUTION PLAN @ @ 05/26/2022: In Process. Work is ongoing for a centralized Linux system management. USNH IT has kicked off the final project phase of the effort, which will pull together the VMWare products installed over the past 6 months into a cohesive software defined Linux and Windows provisioning, configuration, and life cycle management system. This will include server level access and authorization. The due date was extended for the management action plan to September 30, 2022.

(1) A formal periodic network security threat and risk assessment will be performed by December 31, 2019; (2) Network standards and baselines will be developed for the network environment by September 30, 2019; (3) Ongoing monitoring of compliance with relevant network standards and baselines by April 30, 2020; and(4) Further refinement of the roles and delineation of authority between ISS and the network team by September 30, 2019.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/25/2022: (1) Resolved. An formal annual risk assessment over Network Security risks has been completed (2) Resolved. A Network standards and baselines were developed for the network environment. The standard was approved on January 29, 2022 and is effective January 30, 2022. (3) Resolved. Ongoing monitoring of compliance with relevant standards is peformed annually and presented to the USNH CISO and USNH CIO (4) Resolved.

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Jun-20 Dec-22 In Process 05/22

Dec-19 Feb-22 In Process 05/22

41 2019 UNH Donor Restriction & Compliance Audit

Enhance procedures to ensure use of restricted funds is in

accordance with donor terms and restrictions


The network team will collaborate with ISS on the development of security configuration and hardening standards, specifically for the network infrastructure devices, to be finalized by September 30, 2019. Subsequently, the network team will ensure that the standards feasible for the environment will be implemented on each device by December 31, 2019 and any exceptions to the standards will be approved by ISS and documented accordingly. Where possible, two factor will be implemented by December 31, 2019.UNH Network Security Audit39 2019

MGT. EXPLANATION & RESOLUTION PLAN @ 05/24/2022. Resolved: The standards program is underway and operational. A network standard was developed and approved by the Chief Information Security Officer on January 29, 2022 with an effective date of January 30, 2022. In addition, MFA has been implemented for all developers to access routers and servers.

Enhance procedures to ensure gifts are recorded accurately

(1) AVP of Developent and Foundation Treasurer will enhance the fund creation process to include sign-off by Corporate & Foundation Relations director on the documentation and the determination of establishing a foundation-administered fund (December 31, 2019)(2) The AVP of Development, C&FR Director, and Foundation Treasurer will work with UNH SPA to review and update formal guidance regarding the administrations for corporate and foundation fund proposals(December 31, 2019)(3) Director of Advancement Finance will periodically perform a secondary review of related documents on corporate and foundation gifts (December 31, 2019)

MGT. EXPLANATION & RESOLUTION PLAN @ 12/08/2020: (1) Resolved (2) In Process. We have started to draft formal guidance regarding the determination of gifts vs grants. A call will be scheduled with SPA to ensure all aspects of the guidance have been considered. Revised completion date for high-level plan September 30, 2022. (3) Resolved.

40 2019 UNH Network Security AuditLogging and Monitoring The network management team will implement the logging and monitoring process, in accordance with the newly implemented standards

by December 31, 2019.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/31/2022: In process. A standard for Security Monitoring and Log Management Standard was developed. The standard was reviewed by the USNH Director of Cybersecurity GRC on Feb 23, 2022 and approved by the USNH Chief Information Security Officer on February 23, 2022. We are in the process of finalizing the review process over the logs stored in Splunk.

(1) The Associate Vice President for Finance and Administration and the Associate Provost for Academic Administration will review expenditures to ensure compliance with donor restrictions. Review of adjustments made after R+30 for each semester. Retroactive review of adjustments made in the Spring 2019 to ensure they are in compliance with donor restrictions (December 31,2019)(2) The Associate Provost for Academic Administration, the AVPFA, and the Financial Aid Office Director, will revist the process for awarding scholarships, identify any needed refinements, and communicate to appropriate stakeholders (December 31, 2019)(3) UNH Financial Aid Office is in the process of procuring a software solution that improves applications, awarding and tracking process (June 30, 2020)

MGT. EXPLANATION & RESOLUTION PLAN @ 5/31/2022: (1) In process.The focus continues to be shifting financial aid on to the restricted gift funds. Advancement has conducted independent reviews to date. Data gathering is complete for Spring 2019, Spring 2020, Spring 2021 and Spring 2022 and we better understand the size of the project. For scholarships with a GPA requirement, resources in Enrollment Management will be identified to assist with the review. The CERP, other departures and the Huron FAR project have pushed out the expected completion date. Goal is to complete 25% of the review by the end of August 2022, with the full review by the end of December 2022. (2) In Process. Significant progress has been made in more fully incorporating spending plans in the annual budget over the last 3 years, and it continued to be a focus for the FY23 budget. Balances are reported to the UNH CFO on a monthly basis. Some progress was made in FY21 on the release of restrictions, although short of the original goal. Efforts are underway in the schools and colleges to release some level of donor restrictions by the end of FY22, by identifying existing operating expenses that can be used to satisfy donor requirements. Institutional scholarship funds, those managed by Financial Aid and Central Finance, have been and continue to be reviewed for opportunities to financial aid shifts from unrestricted sources. With respect to rules around awarding scholarships, the Director, Central Finance and Director of Finance (Schools & Colleges) still need to develop a high-level plan. Revised completion date for high-level plan December 31, 2022. (3) Resolved: Blackbaud Awards Management has been implemented at UNH prior to the Spring 2022 semester. UNH Students are not able to apply through the system for any open scholardships.

Configuration and Security Hardening

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Jul-20 Feb-22 Resolved 06/22

MANAGEMENT EXPLANATION & RESOLUTION @ 6/1/22: (1) Resolved (2) Resolved (3) Mandatory training for staff will be required by new federal regulations (NSPM33) expected to be finalized in the next few months. UNH has a committee that has been established to comply to with new requirements and mandatory training will be included in the committees initiatives. Since management has substantially addressed the risk. Going forward, the risk is being classfied as medium risk, but will be continued to be followed up until the risk is fully addressed. (4) Cayuse was implemented in February 2022 providing export controls notices and reporting to Export Controls for compliance and monitoring. (5) Resolved (6) Resolved (7) Resolved

2020 UNH Export Controls

Improve controls over the identification, tracking and

monitoring of export-controlled projects and technology control

plans

(1) The University is transitioning electronic research administration systems from InfoEd to Cayuse. Cayuse is a more robust system that will provide integrated reporting. In the interim, CEC will request monthly reports from the senior programmer starting in December 2019. (2) We will revise the proposal routing form questions, as part of the Cayuse implementation, to identify red flags that the export compliance staff could then follow up on. We anticipate that this will be completed by June 30, 2020.(3) Export control training will be required for staff on export-controlled projects by June 30, 2020.(4) Cayuse is anticipated to launch on July 1, 2020, where export compliance information will be linked to the actual project record and will offer more timely and usable management information. In the interim, our current spreadsheet solution will be enhanced to include key fields and reflect the current status of export-controlled proposals and projects by February 29, 2020. (5) To enhance monitoring of TCP compliance, we will incorporate an annual recertification process for active TCP’s. We anticipate that this will be completed by March 2020.(6) Going forward, we will download reports of all RPS activity on a quarterly basis. We will improve our record retention protocols by July 1, 2020. (7) We will perform RPS on personnel listed on active TCPs by January 31, 2020.


Enhance procedures to track gift restrictions accurately and

completely

(1) UNH Director of Advancement Finance will sample new gifts monthly to ensure proper setup and purpose (December 31, 2019)(2) UNH Director of Donor Relations & Stewardship will oversee the Sharepoint Gift Agreement tool enhancement to formalize the mechanism to notify the appropriate BSC when a new gift fund is created (December 31, 2019)(3) UNH Foundation Treasurer and Director of Donor Relations & Stewardship will create a comprehensive process to review fund documentation and update any inconsistencies in Banner Finance. There will be three review goals (September 30, 2020, September 30, 2021, and September 30, 2022)(4) UNH Foundation Treasurer will ensure all BSCs are aware of the process to gain access to ApplicationXtender (December 31, 2019)(5) UNH Foundation Treasurer and Director of Donor Relations & Stewardship are working to clarify when a new gift fund is needed after a gift agreement amendment (December 31, 2019)(6) UNH Director of Donor Relations & Stewardship will outline and disseminate the gift purpose amendment process to BSC Directors, VPFA and Provost staff (December 31, 2019)(7) UNH Foundation Treasurer and Director of Donor Relations & Stewardship wil ensure ApplicationXtender includes all documentation regarding the designated purpose for all gift funds (September 30, 2020)(8) UNH Financial Aid Office is in the process of procuring a software solution that improves applications, awarding and tracking process (June 30, 2020)

44

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: (1) Resolved (2) Resolved (3) In Process. Progress on this project has slowed due to other priorities. The project is on schedule and this will be completed by September 30, 2022. (4) Resolved (5) Resolved (6) Resolved (7) In Process, Management is focusing on developing gift charters for internally designated gift funds where none exists. The few donor-established gift funds without founding docs (older funds) will have a page added to Xtender noting "no documents available". Given several higher gift management/spending priorities and limited risk, we plan to complete this portion of the project will be completed during FY22 (by June 30, 2022). (8) Resolved: Blackbaud Awards Management has been implemented at UNH prior to the Spring 2022 semester. UNH Students are not able to apply through the system for any open scholardships.

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45 2020 UNH Identity Access Management

Enhance security configurations

(1) UNH IT agrees that a security assessment of the OIM replacement should be conducted by 12/31/2021. (UNH Information Technology Manager)(2) By 10/1/2020, the IAM team will review the benefits of setting up a process for feeding OIM application logs to Log Insight with the SADA team. The SADA team will increase OIM log retention to 30 days. Once a SIEM is in place and a USNH process for creating, managing, monitoring security events is created, the IAM team will work with ISS and SADA to support the new process. Estimated completion date 1/1/2022. (UNH Information Technology Manager)(3) By 6/30/2020, Service Account passwords will be changed in accordance with the new USNH Password Policy. Passwords will be stored in the new IT PAM/Password Vault when available. (UNH Information Technology Manager)(4) We have no plans to utilize the encryption in the database for tables and columns since the encryption in place today is being enforced using the Oracles native encryption via the OIM application. Consequently, the DBA cannot see sensitive data and we would be encrypting data already encrypted via the application. For traffic between the database and computer connections we will implement encryption by 4/28/2020. (Senior Information Manager)(5) Standard operating procedures will be modified to outline what the database SYS account will be used for. UNH IT will set the parameter to move the audit files where DBAs cannot modify them. UNH IT will build a report from the audit records outlining the activity of the SYS account and review quarterly. We will evaluate expanding our database privilege account monitoring beyond SYS. The above will be completed by 1/1/2021 (Senior Information Manager)(6) Failed database login attempts are set to 10 on all accounts. All accounts will follow this policy by 6/30/2020. (Senior Information Manager)(7) A periodic review of access will occur twice a year by 1/1/2021. (Senior Information Manager)(8) We will evaluate the Listener settings of our current network design. We will also evaluate our compensating controls and determine if we should enable any or some of the Listener capabilities to complement our current mitigations by 1/1/2021. (Senior Information Manager)

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: (1) - (4) In Process. The Identity and Access Management team is continuing to transition from OIM to Sailpoint for identity management. USNH will be 100% using Sailpoint in the March 2023 Time Period. The team is continuing a proof of concept of using Azure AD for access management and the results will not be known until September-October 2022. These implementations will ensure that USNH is secure and compliant with industry standards. In addition, when transition is complete testing by a third party will take place to verify security. USNH Cybersecurity is looking at instituting MFA for all accounts proving higher level of security that is required by FERPA, GLBA, and HIPAA. The due date was extended for the management action plan to October 31, 2022. (5) In Process. Progress has been made on this outstanding audit issue. The due date was extended for the management action plan to September 30, 2022. (6) In process. The IAM team is currently on schedule to come off of OIM and onto Sailpoint as it's identity store in September of 2022. The IAM team is currently in a POC for Azure AD as the authentication means. These implementations will ensure that USNH is secure and compliant with industry standards. In addition, when transition is complete testing by a third party will take place to verify security. The due date was extended for the management action plan to October 31, 2022. (7) In Process. Progress has been made on this outstanding audit issue. The due date was extended for the management action plan to September 30, 2022. (8) In Process. Progress has been made on this outstanding audit issue. The due date was extended for the management action plan to September 30, 2022.

46 2020 Identity Access Management

Accountability and responsibility

The newly formed IAM team is currently in the process of defining and documenting a clear governance structure. As part of the initiative to replace OIM, documentation will be created to cover the areas described above for the new system, which will manage, track, and report (quarterly).

By 1/1/2021, the IAM manager will provide documentation on the governance structure of the IAM ecosystem.

The IAM manager will raise the lack of OLA standards and requirements across USNH IT to the CIO’s Office for prioritization.Responsible Party: Information Technology Manager, UNH

UNH

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: In Process. The IAM Team falls under the Director of Cyber Security OPS & Identity & Access Management. The Director ensures that the IAM team is on time with it's deliverables and is compliant with it's solutions in regards to regulations, policies & procedures. The due date was extended for the management action plan to October 31, 2022.

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49 2020 UNH Change Management

Streamline policies and procedures

(1) Confirm that the UNH Change Management Program will be adopted for use across USNH to meet the needs o the new USNH ET&S organization (Director of ET&S Help Desk Services and Senior Leadership) Due September 30, 2020(2) Escalate to the ET&S Senior Leadership and CIO to implement a formal SDAMLC charged with clearly defining and required activities, documentation, segreation of duties, approvals, and audit trail artifats required for any change to a production ET&S system or environment (AVP, Information Technology, UNH) Due July 31, 2020If the decision is made to move forward as outlined in (1), then:(3a) Implement an annual review cycel for the Change Management Progam (Director of ET&S Help Desk Services and Senior Leadership) Due January 31, 2020(4a) Develop and implement an annual training requirement for all change management participants to be rolled out ET&S wide as part of the expansion of the exisitng UNH Change Management program to all USNH ET&S (Director of ET&S Help Desk Services and Senior Leadership) Due May 31, 2021If the decision is made NOT to move forward as outlined in (1), then:(3b) Document requirements that should be considered when developing the go-forward Change Management Program and the SDAMLC for USNH ET&S to ensure gaps identified are included in the design of those processes/programs (CMT) Due November 30, 2020

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022 (1) Resolved. The Change Management audit findings were review and discussed at the Enterprise Leadership Committee on Dec 8, 2021. The Service Line Leaders and Orchestrators were asked if they were in agreement with Action 1 listed below. All respondents were in agreement with adopting the UNH Change Management Program across USNH. (2), In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022. (3a) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022.. (4a) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022. (3b) Resolved. A decision was made to move forward to adopt the USNH Change Management Program across USNH.

2020 UNH Identity Access Management

Disaster recovery and business continuity

47 2020 UNH Identity Access Management

48

(1) IAM manager will work with SADA to review and update existing disaster recovery plans and review risk assessments with the new CISO.(Information Technology Manager, UNH) Due date: 1/1/2021

(2) The IAM team will participate in an any future IT-wide business continuity plans development efforts. (Information Technology Manager, UNH) Due date: 1/1/2021

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022 (1) & (2) In process. As Sailpoint comes online in September 2022, DRA planning will be taken into account with redundant locations being established. This will need to be tested on a BI-Annual basis. The due date was extended for the management action plan to October 31, 2022.

(1) Code is managed in subversion, which provides both versioning and code comparison capabilities. Code is designed, developed and unit tested in the OIM development environment by the OIM developer team. When ready, it is deployed first to OIM test for system testing and then to production by one of two system administrators with the appropriate access. While UNH IT perceives the risk of one of the two administrators modifying the code prior to deployment to be low, IAM will raise the issue with ISS and the new CISO. Estimated completion date 10/1/2020. (Information Technology Manager, UNH)(2) By 10/1/2020, the IAM team will raise the segregation of duties issues with ISS and the new CISO for risk assessment and prioritization. (Information Technology Manager, UNH)(3) By 8/1/2020, the IAM Team will implement both a biannual review/attestation of system administration access to the OIM application. Additionally, approvals for new access will be formally documented and the evidence retained prior to granting any new access. (Information Technology Manager, UNH)(4) By 1/1/2021, for each OIM target system (Canvas, Kaltura, Team Dynamix, etc.), the IAM Team will document the account lifecycle supported by OIM. (Information Technology Manager, UNH)(5) By 1/1/2021, the service owner for each of the target systems will review and approve the account lifecycle and document the baseline access provided to a user when OIM creates accounts in that system. (Information Technology Manager, UNH)

Access management

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022 (1) - (2) In Process. The IAM Team is continuing it's transition from OIM to Sailpoint Identity management. It is concurrently working with upgrade to Secure Auth 9.2 and the possibility to transition to Azure AD. Both solutions are scheduled to be ready for the Sept 2022 POC timeline. The due date was extended for the management action plan to October 31, 2022. (3) In Process. This finding will be reviewed in June of 2022 with GRC and Desktop Support Directors. The due date was extended for the management action plan to October 31, 2022. (4) Resolved. (5) In Process. The IAM Team is continuing it's transition from OIM to Sailpoint Identity management. It is concurrently working with upgrade to Secure Auth 9.2 and the possibility to transition to Azure AD. Both solutions are scheduled to be ready for Sept 2022. The due date was extended for the management action plan to October 31, 2022.

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(1) Escalate to the ET&S Senior Leadership and CIO to implement a formal SDAMLC charged with clearly defining and required activities, documentation, segreation of duties, approvals, and audit trail artifats required for any change to a production ET&S system or environment (AVP, Information Technology, UNH) Due July 31, 2020

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022: (1) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date has been extended to November 30, 2022.


Pre-Approved standard changes (PAS)

(1) Changes are categorized based on a risk assessment that takes into consideration a number of concrete factors that, based on historical evidence and industry guidance, increase the risk of certain types of changes. A reassessment of the changes being categorized as system maintenance and preapproved will be performed for appropriateness. (Director and the Enterprise Technology & Services (ET&S)) Due May 31, 2021

If the decision is made to move forward as outlined in the finding Streamline policies and procedures, then:(2) Perform a review of all existing PAS changes in 2020/2021 and determine the appropriate frequency for this review going forward. Formal sign-off on review of the PAS changes for a service line will be required from the service line leader. A SOP for conducting and documenting the review will be developed. (CMT) Due March 31, 2021(3) Modifications to the existing Change Management Model will be implemented to capture and store the rationale for approving all new PAS changes. Best practices/SOPs will be updated to capture this new requirement. (CMT) Due October 31, 2020

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022: (1) - (3) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022.

52 2020 UNH Change Management System maintenance changes

This statement is made based on the fact that the auditor reviewed change-related issues occurring over the past year. In practice, outages are investigated immediately, and system logs are more readily and consistently available than they are months out from an issue.

If the decision is made to move forward as outlined in the finding Streamline policies and procedures, then:As part of the initiative to expand change management ET&S wide, analyze all changes currently designated as system maintenance changes to define a clear set of boundaries for what can and cannot be a system maintenance change. With that definition, perform a return on investment (ROI) analysis that compares the cost of implementing the additional controls recommended by Internal Audit against the actual risk mitigation achieved with those controls. Based on the results of this analysis, make a recommendation to service line and ET&S Senior Leadership (orchestrators) on the appropriate go-forward approach to system maintenance changes, including a SOP. Address any Internal Audit recommendations that are not selected for implementation via formal risk acceptance. (Director Enterprise technology and services (ET&S) Help Desk Services and CMT) Due May 31, 2021

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022: (1) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022.


Enhance code migration restrictions


Improve emergency change process

If the decision is made to move forward as outlined in the finding Streamline policies and procedures, then:(1) Modify the Change Management Program such that the approval of the director/service line leader for all emergency changes must be provided to the CMT and stored as part of the emergency change request. Socialize process change with requestors. (CMT) Due date September 30, 2020(2) Modify the Change Management Program such that all emergency changes that occur between CAB meetings will be reviewed and documented at the next scheduled CAB meeting. Socialize process change with requestors and CAB. (CMT) Due September 30, 2020

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022: (1) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022. (2) In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022.

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Nov-20 Sep-22 In Process 05/22

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2020 UNH

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: In process. Data stewards, their technical delegates, and ET&S continue to meet regularly to work through security classification issues. Main offices - Registrar, Financial Aid, Admissions, and Business Services have worked to create new security groups that contain only objects from their data areas. New individual classes continue to be developed for other campus offices as the needs arise. These outside office classes limit the access to only the objects needed for a specific task. The data steward working group made recommendations to the Account Management System (AMS) team for the account request process that would reduce confusion by the requestor, and provide individual office approvals rather. AMS has not provided a time line of implementing these changes. The new due date for the management action plan is September 30, 2022.

Financial Aid Data Security Review

Enhance periodic access reviews

Management concurs with this finding. In response, periodic appropriate access review protocols and guidelines will be developed and implemented by November 30, 2020. The protocols and guidelines will include the ability to modify or remove access, as necessary. In the development of protocols and guidelines, work with other data stewards to arrive at best practices across similar data steward areas will be attempted. The first review will be completed by November 30, 2020. (UNH Director of Financial Aid)

58


Monitoring of changes for appropriateness

Escalate to the ET&S Senior Leadership and CIO to implement a formal SDAMLC charged with clearly defining and required activities, documentation, segreation of duties, approvals, and audit trail artifats required for any change to a production ET&S system or environment (AVP, Information Technology, UNH) Due July 31, 2020

MGT. EXPLANATION & RESOLUTION PLAN @ 06/08/2022: In process. USNH IT is currently working on developing a Change Management program that meets the needs of the USNH ETS organizations. The standard will be utilizing the report as a guide when developing the Change Management program. The due date was extended to November 30, 2022.

Financial Aid Data Security Review


(1) Develop and implement security protocols and guidelines for handling sensitive data as mentioned in the audit report.(2) Develop requirements to redact sensitive information where possible. When this is not possible, stricter data protection requirements will be implemented.(3) Ensure security protocols and guidelines are reviewed by UNH Information Security Office prior to implementation.(4) Develop and implement protocols and guidelines to securely purge obsolete documents that are stored on ApplicationXtender, UNH Box, shared drives, and Dynamic Forms.(5) Develop and implement protocols and guidelines that ensure all sensitive documents are either placed in a secure location or placed in locked shredding cabinets at the end of the business day.(6) Develop and implement protocols and guidelines that ensure all cabinets and rooms that contain sensitive information are locked at the end of the business day.(UNH Director of Financial Aid)

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: (1) - (6) In process. The UNH Director of Financial Aid is working with UNH cybersecurity to develop uniform standards and procedures that can apply across the institution. The new due date for the management action plan is September 30, 2022.

55 2020 UNH Financial Aid Data Security Review

Restrict access to sensitive data in Web Report Service

The Financial Aid Office will work with USNH Information Technology, the unit responsible for security of the Web Report Service, to resolve financial aid report access by October 31, 2020. (UNH Director of Financial Aid)

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: In process. Financial Aid Office has reached out to USNH Information Technology, the unit responsible for security of the Web Report Service, to resolve financial aid report access. USNH IT is currently evaluating the best ways to restrict access to Web Report Services. The due date was extended for the management action plan to September 30, 2022.

56 2020 UNH Financial Aid Data Security Review


(1) Contact the UNH Information Security Officer and request a vendor security review over Shred-It USA LLC.(2) Contact USNH Procurement Services and request an updated contract be drafted and signed with the vendor; the request will include asking that all appropriate data security language be included by USNH Procurement Services and the vendor.(3) Contact UNH Facilities, to include representation in the discussion outlined in Management Action Plan item 2., in the preceding paragraph. (UNH Director of Financial Aid)

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: (1) The UNH Director of Financial Aid contacted the UNH Information Security Office and requested a vendor security review over Shred-IT USA LLC. This will be completed once a new contract is in process (2) Contacted USNH Procurement Services and requested an updated contract to be drafted and signed with the vendor (3) Contacted UNH Facilities, to include representation in the discussion for the new contract. The due date was extended for the management action plan to September 30, 2022.

2020 UNH

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Mar-21 Sep-22 In Process 05/22

Dec-20 Apr-22 Resolved 05/22

59 2020 UNH Business Services Data Security Review

Initiate periodic access reviews

ET&S developed a report of users who have not accessed Banner in 13 months, and access for those users is removed. Business Services is in the process of getting access to a Banner Student security report. Ownership of Banner Student forms and roles and responsibilities need to be defined across the student services units. Policies and procedures need to be developed, in collaboration with ET&S. A plan will be developed for the initial security review, focusing on the high-risk areas. An employee checklist is used to discontinue access to Banner and all files when employees or student workers leave the department. We will work on the following target dates: Obtain access to the Banner Student security report and confirm that report meets Business Services needs: October 30, 2020; develop risk-based plan for initial security review: December 31, 2020; define roles and responsibilities and procedures: January 31, 2021; initial review: March 31, 2021(UNH Information Technologist, ET&S and UNH Director of Business Services)

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: In process. Data stewards, their technical delegates, and ET&S continue to meet regularly to work through security classification issues. Main offices - Registrar, Financial Aid, Admissions, and Business Services have worked to create new security groups that contain only objects from their data areas. New individual classes continue to be developed for other campus offices as the needs arise. These outside office classes limit the access to only the objects needed for a specific task. The data steward working group made recommendations to the Account Management System (AMS) team for the account request process that would reduce confusion by the requestor, and provide individual office approvals rather. AMS has not provided a time line of implementing these changes. The new due date for the management action plan is September 30, 2022.

60 2020 UNH Business Services Data Security Review

Enhance security for sensitive data

Business Services will review its procedures regarding sensitive information, including secure storage and redaction, and will make appropriate updates. There is a business need to retain sensitive information and procedures will be updated and will be consistent with USNH document retention policies (02-211 Financial Records Retention Periods). Related to the response for finding #2, Xtender for Banner Student is being upgraded in September 2020 and will be part of MFA. (UNH Director of Business Services)

MGT. EXPLANATION & RESOLUTION PLAN @ 06/09/2021: Resolved. The Interim UNH Director of Business Services is reveiwed their procedures regarding sensitive information and made any updates as needed. In addition, Xtender for Banner Student was successfully upgraded in January 2021.

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Sep-20 Dec-21 Resolved 05/22

Sep-20 Jul-21 Resolved 05/22

Mar-21 Apr-22 In Process 5/22

MGT. EXPLANATION & RESOLUTION PLAN @ 6/2/22: (1) The Senior Director, Research & Sponsored Programs met with the NOAA Program Manager and the Principal Investigator on August 27, 2020. The NOAA Program Manager confirmed that direct charging of the scientists' time to the cooperative agreement was appropriate and provided further guidance to meet the voluntary cost share obligation. (2) Resolved. (3) Resolved. (4) Resolved. (5) Resolved. (6) UNH has identified the source of funds to meet the voluntary cost share obligation. PI approved the cost sharing allocation and documentation was maintained in the Xtender. (7) Resolved. (8) Resolved.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/10/22: UNH SPA worked with HR to develop a process for identifying, tracking, and monitoring of E-Verify requirements. UNH Pre-Award will be responsible for identifying federal contracts that E-Verify requirements are applicable, SPA Research Administration Support Services will be responsible for reviewing Banner HR to see if E-Verify has been completed. If not, SPA work with the Pi and HR to complete this verification. SPA is responsible for monitoring compliance with E-Verify requirement through the running of the E-Verify WebI Audit Report twice a week.

Enhance control structure, authority, and responsibility for

institutional data reporting

(1) Management agrees that more central oversight is required for external surveys and reporting. Since these findings were reported, IR&A has reviewed a US News survey for Paul College and will be reviewing additional US News surveys for Engineering and Physical Sciences, Health and Human Services, Liberal Arts, and Paul College before they are submitted. IR&A, working with Academic Leadership, will develop an inventory of survey participation and external data submissions that occur at UNH. Work will be completed by February 15, 2021. (2) Based on the findings from the survey inventory, roles, and responsibilities for the completion of each survey will be established, based upon risk, impact of institutional reputation, and leadership objectives. Work to be completed by March 15, 2021. (3) A central repository of institution-wide surveys will be established to track and monitor the due dates, approvals, and submissions of these surveys. This central repository will provide a framework for survey completion, review, and submission. It will identify and document survey requirements, survey due date, roles and responsibilities for survey completion and reporting integrity, review and approval protocols, and data sources/retrieval approach for each survey. Work to be completed by March 15, 2021. (4) IR&A and Enrollment Management will increase oversight and access to Financial Aid data required for surveys and external data sets. This effort is underway and will be completed throughout the survey cycle period. Common Data Set review will be completed by February 15, 2021, Integrated Postsecondary Education Data System (IPEDS) review will be completed by January 31, 2021. (5) Based on the outcome of the inventory of surveys and level of institutional oversight required, additional data elements will be incorporated into the Center for DATA enterprise data mart. This will be a phased effort and dependent upon the results of the survey inventory, which will be completed by March 15, 2021. A sub-certification process will be developed for areas that provide data to IR&A for external surveys for which IR&A does not have access to or oversight. This process will require submitting departments to certify that the data is accurate, has been reviewed and tested, and meets the survey need/requirement. Work to be completed by January 15, 2021. (6) The processes mentioned above for increasing Center for DATA/IR&A access to and oversight of financial aid data will be in place to ensure accuracy of financial aid data reported in in the 2022 US News survey, which will be due in May of 2021 and published in September 2021. For the interim period between now and May, IR&A will submit corrected financial aid data for the 2021 US News survey which was submitted in June 2020. Although corrections will not change UNH’s ranking, US News makes corrections to its institutional data published on its website. Work to be completed by December 23, 2020.

63 2020

61 2020 UNH

UNH Institutional Data Reporting

Effort Reporting

Enhance controls over allocation of effort

(1) Management will work with the Business Service Center (BSC) to ensure effort charged to the cooperative agreement referenced is in compliance with Uniform Guidance and make any adjustments deemed appropriate. This will be completed on or before July 31, 2020. (2) Management worked with the BSC to adjust the annual effort allocation for the research scientist referenced above in section (i). These adjustments were completed in April 2020. (3) For FY20, Sponsored Programs Administration will require principal investigators to certify the effort for all research staff.(4) For FY20, Sponsored Programs Administration launched a non-mandatory PI Quarterly Expense Certification for all federal sponsored program expenditures. This certification will be made mandatory in FY21.(5) The principal investigator has been reminded that changes to an existing agreement must be made, in writing, between the University and initiated through SPA and the Sponsor’s contract office. (6) Management believes that UNH has fulfilled the voluntary committed cost share through the receipt of third-party agreements. We will appropriately document and report these voluntary committed cost share amounts to the sponsor in the next reporting cycle. If not fully met through third-party agreements, UNH will identify resources to fulfill the cost share obligation.(7) The Grant and Contract Administrators will be reminded of their responsibility to review the proposal to ensure that voluntary cost share is not proposed without the approval of the Senior Vice Provost for Research, Economic Engagement and Outreach (SVPR, EE&O) or her designee. This was reviewed at the June 23, 2020 SPA staff meeting.(8) SPA will incorporate the review of Banner grant setup by AFC Financial Research Administrators during billing setup. This will be completed on or before September 30, 2020.

62 2020 UNH Effort Reporting

Enhance controls over federal contract E-Verify compliance

UNH Research, UNH Human Resources, and BSCs will work collaboratively to develop procedures to process, track, and monitor compliance with E-Verify requirements. E-Verify records related to effort charged on projects subject to E-Verify will be validated to ensure compliance with FAR 48 CFR 52.222-54 requirements.

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Jun-21 Jun-23 In Process 05/22


Jan-22 Jan-22 Resolved 05/22

MGT. RESOLUTION & EXPLANATION PLAN @ 5/23/22: (1)-(3): Resolved (4): Financial Aid data has not been added to the enterprise reporting environment due to capacity/staffing issues and competing priorities. Revised completion date December 2022. (5) and (6) Resolved.

66 2020 UNH Mandatory Fee

Ensure mandatory fees charged are according to approved rates

Mandatory fees for summer and January term are minimal and are currently under review. UNH will work with USNH to determine how mandatory fees for summer and January term should be disclosed in the Board materials. Any changes will be implemented for the January 2022 Board meeting, when mandatory fees are submitted for approval.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: Resolved: Additional footnotes were added to the January 2022 board materials regarding mandatory fees charged during the summer and January term.


Document classification of mandatory fees in the financial

statements

Mandatory auxiliary fees support auxiliary activity, and USNH elected to classify these revenues in alignment with the activity they support. USNH Financial Services will evaluate the existing practice and as part of the policy updates underway to support the Financial Administrative Restructure project and document its justification for the classification by June 30, 2022. The language in MD&A also will be clarified to fully disclose the categories of auxiliary activities for the year ending June 30, 2021.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: In Process. The language in the MD&A was updated to fully disclose the categories of auxiliary activites for the yer ending June 30, 2021. The documentation regarding the classification is now part of a bigger project to define all fees charged to students. This is being completed as part of the chart of account framework that is currently in process. The due date due for the management action plan was extended to June 30, 2023.


Develop formal policies and procedures for mandatory

student fees

As part of the FY23 mandatory fee rate-setting process, the UNH CFO Office will establish formal policies and procedures regarding how mandatory student fees can be used. The policy and procedures will also address travel, including student and team travel, and will reflect compliance with NCAA requirements. UNH will also reinforce existing USNH policies to ensure that the policy is consistently applied to all expense transactions. This will be completed by December 31, 2021.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: In Process: With the CERP and FAR restructuring the progress has been delayed. While much of this was previously documented, updates and enhancements are needed. The CFO office expects to have an updated draft in place for the FY24 mandatory fee process. The due date was extended to December 31, 2022.

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Mar-22 Mar-22 In Process 05/22

Aug-22 Aug-22 In Process 05/22

Jun-22 Jun-22 Resolved 05/22

67 2021 UNH Admission Data Security Review


(1) UNH Office of Undergraduate Admissions uses Hobson’s Naviance to allow transcripts and sensitive information to be submitted. We will continue to use this system and discourage staff from accepting documents via email.(2) Admissions will work on these policies and add to the admissions handbook by March 1, 2022: security protocols and guidelines for handling sensitive data, addressing all of the above recommendations.(3) We will review the USNH Data Classification Policy with the USNH Chief Information Security Officer regarding emailing UNH ID to potential UNH students by December 1, 2021. With the implementation of a new solution called Slate in 2022, we will remove the need to send UNH IDs to students.(4) A document retention policy has been implemented with IT for scanned documents. Paper documents are scanned to the system and physically discarded after 1 year. We will consult with UNH legal regarding this retention policy. This will be completed by January 1, 2022.(5) We will investigate the feasibility of and/or purchasing a dedicated, non-network fax machine for use in faxing and receiving faxed documents with sensitive data. Alternatively, the office may end fax use (both sending and receiving). This will be completed by January 1, 2022.(6) We no longer provide paper documents to offices outside admissions. New processes are in place for electronic access to admission documents to those privy to this information. Approval protocols are in place before access is granted to staff throughout the University. UNH accounts portal is used to monitor requests and workflows are developed to ensure admissions approves any access.(7) We will work internally to develop guidelines for staff to understand which PII information should not be sent via fax, email or printed.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: (1) - (3) Resolved: Data security policies and procedures have been established and added to the training manuals, incuding receiving transcripts via email. The USNH CISO reviewed the data security policies. (4) In process: We are currently working to develop a formal retention policy. The due date was extended to September 30, 2022. (5) In Process: We are currently working with the USNH CISO regarding the fax machine currently in use. The due date was extended to September 30, 2022. (6) - (7) Resolved: Data security policies and procedures have been established and added to the training manuals, incuding receiving transcripts via email. The USNH CISO reviewed the data security policies.

UNH Admission Data Security Review


We will consult with the USNH CRM team to implement MFA for Salesforce TargetX. PSU is going to be first school to enable this and they have been working with the security team to move this to production. Once they have completed their implementation, the plan will be copied to KSC and UNH. The Associate Vice Provost for Enrollment Management and Marketing will work with the USNH Chief Information Security Officer to implement MFA for Salesforce TargetX. This will be completed by June 30, 2022.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: Resolved. Two-factor authentication has been implemented for the UNH/CRM platform Salesforce TargetX.

68 2021 UNH Admission Data Security Review


As contracts expire, we will confirm with the USNH Chief Information Security Officer that vendors are meeting all USNH requirements to protect sensitive student data. In addition, we will contact USNH Procurement services to initiate discussions with vendors to sign an update contract as the contracts expire. We will confirm that all appropriate data security language is included in contracts as they are updated and renewed. Finally, we will work with the USNH Cybersecurity office regarding the review of applicable SSAE 18 reports for all external vendors. This will be completed by August 31, 2022.

MGT. RESOLUTION & EXPLANATION PLAN @ 05/31/2022: In Process. USNH Governance, Risk and Compliance office is currently conducting a 3rd party vendor security assessment review. USNH IT is working with procurement to have this process included in all contract and contract renewals going foward. The due date is currently August 31, 2022.

69 2021

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Aug-22 Sep-22 In Process 5/22


(1) Management will develop grades access policy and protocols that will provide framework for access and authorization in WebCat and Canvas, which will be approved by the UNH Provost. Work to be completed by October 15, 2022.(2) UNH-D management will explore functionality in Banner admin page GTVSDAX to ensure the grade drop down menu in WebCat displays grades associated with a course section. UNH-D and TLT management will explore the redesign of Canvas grade scale menu to be consistent, including IC grade. Work to be completed by March 15, 2022.(3) Registrar and TLT management will work to align WebCat and Canvas grade submission permissions so that all instructors of record (assigned in Banner) have the ability to submit grades for a course in both systems. Management will draft a grades access policy statement to ensure consistency in Banner and Canvas roles. The policy statement will be shared between TLT and Registrar management. Policy statement will address the fact that Banner requires one “primary” instructor on a course. Departments often assign more than one instructor to a course and all instructors have equal roles; one instructor is not designated as “primary” by the department. In this scenario, the “primary” instructor designation is arbitrary, and all instructors have grading responsibilities. Work to be completed by March 15, 2022.(4) University Registrar confirmed with Academic Standards and Advising Committee that instructors must retain the ability to manually add students to Canvas rosters. Registrar management will propose adding text to Canvas that will be displayed when a teacher adds an individual to course roster alerting them of the fact that the student must also submit a formal request to add the course according to university policy. Management notes that an official grade cannot be submitted for a student that has been added to course roster in Canvas but has not gone through the form university procedure to officially add the course. Work to be completed by December 1, 2022.(5) Current procedures exist to identify discrepancies between Banner and Canvas rosters however instructor response rates are low. To address USNH Internal Audit’s concern regarding Canvas users’ ability to add a student to a course, Registrar management will evaluate this current procedure and will investigate improvements in an effort to increase effectiveness. In addition to this, UNH-D and TLT management will investigate a procedure to compare Canvas and Banner course rosters after the add/drop period closes. UNH-D Registrar management will consider outreach to students that have been manually added to the Canvas roster but have not gone through formal university procedure to officially add the course. Work to be completed by June 15, 2022.(6) Registrar and TLT management will review grade passback errors and automated responses to teachers to ensure errors are resolved. As previously stated, management will evaluate Canvas and Banner functionality in an effort to reduce the number of errors produced (see Action Plan 2(2)). Work to be completed by March 15, 2022.

70 2021 UNH Student Grades

Enhance authority, responsibility, and structure

(1) See UNH-L action plans referenced in Appendix I. The UNH Law action plans encompass the following three main areas (1): Return responsibility for submitting individual student grades to faculty. Faculty will directly submit student grades into WebCat/Banner, (2): Clarity and adherence to deadlines and policies. Deadlines will be reviewed, published, and included on all relevant forms. Authority for approvals, and the designated approving authority, will be reviewed and published and identified on all forms. Deadlines will be followed and all deviation from deadlines or standard policies for the 2021-2022 year may only be approved by the Associate Dean of Academic Affairs (ADAA) or, in her absence, the Associate Dean for Administration and Enrollment (ADEA). Possible delegation of this authority will be considered in 2022-2023 after a review of all processes, (3): Form and document review and retention. Work to be completed by August 31, 2022.(2) Create a shared resource that is accessible and maintained by Registrar management at all UNH campuses. UNH-D will create the platform and will include the following documents: 1) operational calendar outlining grade related tasks and deadlines and the staff/campus that will complete work, 2) policies and procedures handbook with designated sections for UNH-D and UNH-M undergraduate programs, UNH-D and UNH-M graduate programs, UNH-L Juris Doctor and UNH-L graduate programs, 3) record of delegation of authority and, 4) USNH Student Grade Audit Report and action plan tracker. UNH-D management will ask management at all campuses to assist in maintenance of the documents. Changes to the documents will be tracked for archival purposes. This will bring consistency and transparency to the work that all campuses do and will ensure that there is a centralized source to aid in procedural improvement, efficiency, authority, and communication. Work to be completed by March 15, 2022.(3) In July 2021, functionality allowing faculty to submit final grade changes via WebCat was implemented. The tool was designed to enforce UNH grade change policy, accuracy, authority, and data security. As of the publication of this report, UNH-D and UNH-M faculty use this functionality. Management plans to make the functionality available to UNH-L faculty in a Phase 2 implementation. Work to be completed by August 31, 2022.(4) Management will work to update Student Rights, Rules, and Responsibilities (SRRR) 07.14(ad) to include a dean’s right to delegate his or her authority. Work to be completed by September 1, 2022.(5) Management will develop a biannual process to review a random selection of grades and grade adjustments processed by all campuses. To ensure review is built into current business processes, management will add this task to the calendar which will be accessible by Registrar management across all campuses. Findings and action taken will be recorded and archived. Work to be completed by March 15, 2022.(6) UNH-D Office of the Registrar will work with the Associate Dean for Academic Affairs to evaluate the Graduate School grade change policy time limits and authorization level. Work to be completed by December 1, 2021.(7) UNH-L will obtain documentation of faculty vote to approve UNH-L Spring Emergency & Operations resolution, which modified Academic Rule IV: Grading for the Spring 2020 semester. If this documentation is not available, UNH-L will retroactively approve the resolution Work to be completed by December 31 2021

MGT. EXPLANATION & RESOLUTION PLAN @ 05/30/2022: (1),(3),(4),(9) In process. Not yet due. Will provide update for January 2023 Audit Committee meeting. (2) In process; UNH Registrar's Office has created the shared resource however several operational calendars need to be linked. Also work is in process on the organization of internal documentation and operating procedures. (5) Grade and grade adjustment reports have been created but review process has not been establised. Revised due date of August 31, 2022. (6) Confirmed with Graduate School Dean that grade change limits do not exist and at the present time there is no need. Graduate School grade changes are approved on a case by case basis. Delegation of authority for the Graduate School was obtained. (7) Retroactive approval was obtained at the December 2, 2021 UNH Law Faculty Meeting. (8) UNH Law Transcript Key was updated to include CR grade definition. (9) The AAAC reviewed Rule IV over AY21/22 and made a modification with regards to time limits for incomplete grades.

UNH202171 Student Grades

Enhance grading system interfaces

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MGT. EXPLANATION & RESOLUTION PLAN @ 05/24/2022: (1),(4) In progress; not yet due. Update will be provided at the January 2023 Audit Committee meeting. (2) UNH-D Registrar's Office is working with TLT on grade access and menus for consistency across applications. Revised due date of August 31, 2022. (3) Registrar's Office has drafted Grade Access Policy Statement. Once it is reviewed, the Registrar's Office will send to TLT for review and statement and alignment regarding Canvas grade access. To be completed by August 31, 2022. (5) In progress. TLT is working to create a report that identifies students who were manually added to Canvas rosters. Once this is finalized, the Registrar's Office will draft correspondence to send to mannually added students during the semester. To be completed by August 31, 2022. (6) UNH-D Registrar's Office is working with TLT on evaluating grade passback functionality and error resolution. Revised due date of August 31, 2022.

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Dec-21 Aug-22 In process 5/22

Aug-22 Aug-22 In process 5/22


Enhance security protocols for student grades

(1) UNH-L will return responsibility for submitting individual student grades to faculty. Faculty will directly submit student grades through WebCat and Canvas. UNH-L will Plan to utilize WebCat Final Grade Change tool as ET&S and Registrar resources are available for Phase 2 implementation.(2) Management developed and implemented the WebCat final grade change tool in July 2021 for UNH-D and UNH-M student grade changes. UNH-L will adopt the grade change tool by August 2022.(3) UNH-D management acknowledges that the submission of student grade forms via university email is not best practice. Campuses were forced to alter standard practices to accommodate remote work due to the COVID-19 pandemic. Student grade forms are only accepted from UNH-D and UNH-M faculty when sent using a UNH email address. UNH-D Office of the Registrar will contact other New England Land Grant institutions to learn how registrar forms are submitted, reviewed, and approved. Based on findings, management will draft a plan to improve current submission process.(4) UNH-D management will develop security protocols and guidelines for handling student grade information and registrar forms and will publish on the Registrar FERPA webpage. UNH-D management will request to the Provost that UNH-M and UNH-L link to UNH-D's FERPA webpage to ensure consistency across all campuses.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/20/22: UNH Registar's Office is working on adjusting reporting to allow for efficient and accurate review.

MGT. EXPLANATION & RESOLUTION PLAN @ 05/24/2022: (1) In process; Update will be provided for January 2023 Audit Committee Meeting. (2) In process; Update will be provided for January 2023 Audit Committee Meeting. (3) App Admin changed the dummy emailed addresses for student workers to the App Admin mailing list [email protected]. (4) In process, TLT is currently working with Cybersecurity on best practices with regards to management of local accounts. In the interim, TLT is developing new processes to enhance security of local accounts. Work to be completed August 2022. (5) In process. An update will be provided for the January 2023 Audit Committee meeting. (6) App Admin has in place a bi-annual review of local admin passwords to vet and update passwords. We are working with Cybersecurity to create a system to store these passwords in a password vault. The vault is currently being updated. Revised due date of August 31, 2022. (7) Student admin privileges were changed to remove ability to masquerade as an instructor or to view or modify grades. (8) In Sept 2021, the App Admin Manager created an audit log to track student activity. This review is done every other month and the instructions for what should be reviewed is included in the log. Student workers are now required to complete the UNH Cybersecurity Training required of all ET&S employees. All current student workers have completed this training. (9) In process. (10) In process. The list of users has been created and reviewed by USNH HR. HR has identified user that no longer have a job role at UNH. Registrar's Office is working on the termination of access. Review of remaining users will be completed by the end of the summer 2022. (11) UNH-D continues to create new, streamlined security classes. As existing security classes are reviewed, objects that are not appropriate for the class are removed. This is a work in progress to be completed by end of summer 2022.

73 2021 UNH Student GradesEnhance transfer credit process

UNH-D management will use available reporting to identify high risk transfer credit awards and will evaluate the records for accuracy and compliance with UNH transfer credit policy. To ensure review is built into current business processes, management will add this task to the calendar which will be accessible by Registrar management across all campuses. Findings and actions taken will be recorded and archived.


Enhance periodic access review and monitoring

(1) The admin account access review process will be documented and will include limiting who has access, justification of access, and how credentials are to be stored by November 30, 2021. (2) The Application Administration (App Admin) team will document the approval process of changes to permissions and additions of roles. These changes and who approved these changes will be tracked in a separate audit/change log specific for admin rights by November 30 ,2021.(3) In June 2021, App Admin changed the dummy email addresses for student worker local accounts to the App Admin mailing list [email protected]. Emails sent to this email address are received by App Admin team. If there is a change to the student admin account, the App Admin team, including the manager, will receive a notification. (4) TLT will reach out to the Cybersecurity team to discuss best practices for creating admin accounts and will work on a process that follows their suggestions for securing the accounts by November 15, 2021. (5) Currently, there is no password vault that we are able to store account passwords. Since we need to share some admin account information, management agrees that we will continue to store passwords in a folder accessible to only the App Admin team. ET&S is planning to roll out a password vault tool and once that is rolled out, App Admin will use that tool and no longer store passwords in OneDrive. Work to be completed by October 31, 2022. (6) App Admin will put a process in place to annually change local admin account passwords in line with USNH password policy. Also, the password will be changed when there are changes in App Admin staff. Once the password vault tool is rolled out this process will be automated. Work completed by October 31, 2022.(7) Student admin privileges were changed in June 2021 during the audit process, and they no longer have admin accounts that allow masquerading as an instructor or the ability to modify or view grades. (8) The App Admin team will document the steps involved with auditing the student admin account activity. An audit log will be created to record the time and the name of the person that completed the audit along with any findings. Also, the App Admin team will increase the auditing of student admin accounts to bi-monthly. The App Admin manager will review the audit log quarterly to ensure audits are happening and there are not any concerning activities such as off hours access, pageviews in areas they should not be etc. Student workers sign the ET&S confidentiality and cyber security agreements. The Director of TLT Application Administration and User Support will discuss the possibility of holding data security training for TLT student workers with the USNH Cybersecurity group. Work to be completed by December 31, 2021.(9) Management will develop grades access policy and protocols that will provide framework for access and authorization in WebCat and Canvas, which will be approved by the UNH Provost by October 15, 2022.(10) Management will implement an annual review of Banner Student grade admin pages (SFASLST and SHATCKN) access using WebI report SIS00100. User maintenance and query access will be adjusted based on users’ current position and job responsibilities. To ensure review is built into current business processes management will add this task to the calendar which will be accessible by Registrar

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Dec-22 Dec-22 In process 5/22

MGT. EXPLANATION & RESOLUTION PLAN @ 5/20/22: (1) Starting in the Fall 2021 semester, UNH-Law faculty entered grades in Webcat. (2) In progress. Not yet due. Update will be provided at January 2023 Audit Committee meeting. (3) UNH will discuss with peer institutions at July 2022 New England Land Grant Meeting. (4) In progress.

75 2021 UNH Garage Inventory

Enhance inventory receipt process

(1) UNH Management will evaluate if staff will be formally investigated about the missing parts. This will be complete by December 31, 2021 by the UNH Associate Vice President for Facilities and Operations(2) The Transportation Garage has been rolled into UNH Facility Services. Facilities Services is in the process of implementing a new work order platform called Assetworks, (AiM). AiM will allow all work, parts inventory, and procurement to be captured on one platform. In addition, by adding the transportation garage stockroom to the Facilities Operations Warehouse, all established policies and procedures will be adopted for the garage operations, which includes, use of AiM to capture all inventory, as well as recording returns. This will be completed by December 31, 2022 by the UNH Associate Vice President for Facilities and Operations. (3) By adding the Transportation Garage stockroom to the Facilities Operations Warehouse, all established policies and procedures will be followed which includes, use of AiM to capture all inventory, as well as recording returns. In addition, segregation of duties for receiving and recording vehicle parts will be implemented. This will be completed by June 30, 2022 by the UNH Associate Vice President for Facilities and Operations.(4) By utilizing the Facilities Work order system, AiM, the review of work orders will be the following: 1) Fleet mechanic completes work which is documented in AiM including parts used and 2) Service writer and/or manager verifies every AiM work order by checking workmanship and the documentation within the work order correctly describes work and parts used. This will be completed by June 30, 2022, based on the capabilities of AiM by the UNH Associate Vice President for Facilities and Operations. (5) We will reinforce existing USNH policy on supporting documentation. All purchases will be documented through AiM as they currently are at the facilities operations warehouse. This will be completed by June 30, 2022 by the UNH Associate Vice President for Facilities and Operations.(6) We will reinforce existing USNH policy on documenting business purpose before approving the transaction. All purchases will be approved through AiM and UShopNH. This will be completed by June 30, 2022 by the UNH Associate Vice President for Facilities and Operations.(7) We will periodically review access over AiMs to ensure least privilege principles and segregation of duties apply. The first review will be completed and documented by March 31, 2022, based on the capabilities of AiM. by the UNH Associate Vice President for Facilities and

MGT. EXPLANATION & RESOLUTION PLAN @ 05/31/2022: (1) Resolved. UNH Management has evaluated the incident and determined that nothing has risen to the level of any further investigation. (2)-(6) In Process. The due date for the management action plan is 6/30/2022. (7) As AIMs was just recently implemented, an access review hasn't been completed yet. The due date has been extended to December 31, 2022.

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Jun-22 Jun-22 In process 5/22


Jul-22 Jul-22 In Process 6/2279 2022 UNH Financial Aid Data Verification

Process

Enhance compliance with Title IV federal financial aid requirements

(1) Management will create financial aid policies and procedures in the areas identified above and included in the Appendix. Specifically, in the following areas: financial aid verification and reporting including required elements defined by 34 CFR 668.53, processing of changes to verification documentation and FAFSA data and supporting documentation requirements, use of professional judgement, and identification of conflicting information. (2) Management will report V4 and V5 verification results and professional judgment adjustments, as required. (3) Management will develop supporting documentation and retention protocols. (4) Management will develop a process for the periodic review of verification documentation.(5) Management will obtain missing information on the student’s dependent verification worksheet and adjust aid, as appropriate. (6) Management will develop a process to periodically monitor FAFSA corrections and updates.(7) Management will monitor and require approval for overrides and exceptions. (8) Management will obtain accurate or missing documentation, correct calculation errors, and recalculate federal financial aid eligibility, after thorough review. Management will then take appropriate action based upon the risk associated with recalculated eligibility. (9) Additional training will be provided to financial aid staff on policies, procedures, and protocols.

MGT. EXPLANATION & RESOLUTION PLAN @ 6/1/2022: NEW


Enhance control structure, authority, and responsibilities for

UNH Operations

We will develop formal policies and procedures regarding the day-to day operations, including but not limited to roles and responsibilities of the staff, the receiving and recording of inventory parts, procurement of inventory parts and tools, recording of inventory cost, review and verification over repairs, and the acceptable use of UNH Garage facilities. As previously stated, the transportation garage has been rolled into Facilities and has gone through a re-organization. Under the direction of the Executive Director of Facilities Services, the Transportation Garage Manager currently oversees the shop service writer, stockroom clerk, part time bookkeeper, lead fleet mechanic, and three fleet mechanics. As part of roll over into Facilities and once AiM has been fully installed, the stockroom clerk will move over to the Facilities Warehouse and report to the Facilities Materials Manager. The Facilities Warehouse, as described previously, already has the means and methods in place to handle the current and future inventory for parts needed to operate a successful garage. It is the responsibility as described as essential job functions of the fleet mechanics to properly account for parts and inventory items. Likewise, as described as an essential job function for the Transportation Garage Manager to verify that all parts and inventory used by the garage are properly accounted for. This will be completed by December 31, 2022 by the UNH Associate Vice President for Facilities and Operations.

MGT. EXPLANATION & RESOLUTION PLAN @ 06/01/2022: In Process. The due date is December 31, 2022.


Enhance annual inventory verification

(1) We will implement established policies and procedures from UNH Facilities Services. Facilities Services will supervise the inventory process and obtain supporting documentation if the year-end count needs to be adjusted outside of the count. This will be completed by June 30, 2022.(2) Every single part is given a bin location regardless of value. The bin is included in the year end count and counted regardless of value (even zero value items soap dispensers etc.). This will be completed by December 31, 2022 by the UNH Associate Vice President for Facilities and Operations.(3) We will establish a process to identify annually any vehicle parts that are potentially in excess and should be removed from the inventory and written off. Reports are developed that show when parts are received, placed in, and taken out of inventory. We will use these reports to determine if the part should still be in inventory or if the part needs to be removed from inventory and written off. This will be completed by December 31, 2022 by the UNH Associate Vice President for Facilities and Operations.(4) With the implementation of AiM, every single part will be received into inventory and “sold” out of inventory, including no cost items. Special order parts will continue to be recorded on purchase orders and charged out to work orders as well. These procedures will maintain the inventory accurately and with the 3 -way match the inventory cost will be accurately recorded in the inventory. In addition, this creates a trail that is easily navigated to see cost and to run reports that would show what campus entity bought an item (housing, operations locations, campus customers etc.). This will be completed by December 31, 2022, based on the capabilities of AiM by the UNH Associate Vice President for Facilities and Operations.(5) Any discrepancies found will be brought to the stockroom manager’s attention. The manager will be the only staff member that has permission within AiM to make any adjustments. In addition, the stockroom manager will request any supporting documentation to support the adjustments. This will be completed by December 31, 2022 by the UNH Associate Vice President for Facilities and

MGT. EXPLANATION & RESOLUTION PLAN @ 06/01/2022: (1) In Process. The due date is June 30, 2022. (2) - (5) In Process. The due date is December 31, 2022.


Enhance billing and collection process

(1) The decision was made to no longer provide services to non-UNH entities. This has been completed on August 5, 2021(2) We will review all unbilled work orders to external parties to ensure reimbursements are received and revenue is recorded. This will be completed by June 30, 2022 by the UNH Associate Vice President for Facilities and Operations. (3) UNH Management determined that markups on parts and services will be discontinued and internal UNH departments are billed these services at cost. This has been completed by July 1, 2021.

MGT. EXPLANATION & RESOLUTION PLAN @ 06/01/2022: (1) Resolved (2) - (3) In Process. The due date is June 30, 2022.

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80 2022 UNH Financial Aid Data Verification Process

Enhance controls over system configurations

(1) Management will update the current system testing plan documentation to include test plan details and supporting documentation of testing, review, and approval. (2) UNH has completed verification on the student noted above and there were no changes to the student’s federal aid eligibility. (3) Management is updating current system configurations to align with current processes. As financial aid processes evolve over time, management will continue to review and update system configurations.(4) Management reviewed all other students to ensure this case was isolated and confirms that there were no other students in this situation aside from the one student noted in the audit. Management made system changes to prevent this situation in the future. Staff have monitored processing weekly throughout the spring semester and confirms that the revised system configuration is working properly.(5) Edit access to RHACOMM is not a baseline student system item and cannot be modified by the Financial Aid office. However, management will update protocols with staff to require a new comment rather than editing existing notes. Further, management will put in place review protocols to periodically review comment creation and activity dates to ensure compliance with protocol.


81 2022 UNH Athletics Cash Carrying & Depositing

Ensure appropriate recording of Athletics revenues

(1) Management will evaluate organizational and staffing structure for effective and efficient processing of Athletics revenue, while considering segregation of duties. As part of this process, management will formalize and document roles and responsibilities. Work to be completed by December 1, 2022. (2) Management will review and create an inventory of Athletic cash sales and fundraising activities by July 1, 2022.(3) Management will develop Athletics departmental policies and procedures, which will be communicated to constituents. Work to be completed by December 1, 2022. (4) Management will develop a Box Office desk manual by July 1, 2022. Season ticket protocols and ticket transaction processing and adjustments will be incorporated into this manual. (5) Training will be provided to staff on Athletics policies and procedures and Box Office operations. Also, Athletics staff will participate in University-wide training opportunities and coordinate with UNH Finance for training and guidance on USNH and campus revenue policies and procedures. Work to be completed by December 1, 2022. (6) Management will reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions. Work to be completed by December 1, 2022.(7) Management will develop a formal receipting process for manual cash receipts, while looking to reduce cash transactions and leveraging credit card options. Work to be completed by December 1, 2022.(8) Management will develop processes and procedures related to complimentary tickets and internal ticket transfers by July 1, 2022.(9)Management will work with Audience View and USNH Treasury to integrate Audience View and Pay Conex. Work to be completed by September 1, 2022.(10) Management will develop a process for the review of game revenues for reasonableness, incorporating presales, gameday sales, and scan counts to be completed by September 1, 2022. (11) Athletics is moving towards self-service and mobile ticket functionality. As part of this initiative, season tickets will not be active until payment has been made in full. As a result, there will be no season tickets accounts receivable. Work to be completed by September 1, 2022.(12) Management will follow-up with customers who have an outstanding season ticket accounts receivable balance due and determine appropriate action by September 1, 2022.(13) Management will review credit card chargebacks as part of the monthly review and allocation of Athletics credit card activity. Work to be completed by September 1, 2022.(14) Management will work with Audience View staff to configure application with user roles, integrate credit card processing, and ticket reporting to be completed by September 1, 2022.(15) Management will review and correct ticket transaction entry errors in Audience View by July 1, 2022. (16) Athletics will evaluate opportunities to minimize manual cash activities and leverage technology and credit card options Work to be



Enhance procedures to ensure compliance with USNH Fraud

policy

(1) Management will review transactions referenced above for appropriateness and take action, as appropriate. (2) Management will reconcile Audience View ticket transactions to PayConex, and Banner Finance. Any variances will be reviewed, followed up, and resolved.(3) UNH Athletics Ticket Office staff will work with Audience View to adjust system configurations to enhance controls over ticket processing and adjustments.


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91/22 Sep-22 In Process 6/2285 2022 UNH Athletics Cash Carrying &

Depositing

Enhance security of payment card data

(1) Athletics management will develop procedures for processing payment card transactions and handling of related data to comply with USNH policy 10-010 USNH Payment Card Data Security. These procedures will be incorporated into the UNH Athletics Box Office desk manual. (2) Individual user accounts will be setup in PayConex to comply with PCI DSS Requirement 8. (3) Management will periodically review PayConex access for appropriateness. (4) Athletics management will work with USNH Treasury to review credit card swipe terminals and computers used in processing of Athletics credit card activity for compliance with PCI DSS requirements. (5) Management will notify staff that user credentials should not be stored in electronic files. (6) Background checks are performed on employees and student interns who have access to PayConex. Also, PCI-DSS training is provided to staff and student interns. Athletics management will work with USNH Treasury to track training to ensure that training is completed to meet PCI-DSS requirements.



Enhance cash handling and depositing process

(1) Management will develop Athletics departmental policies and procedures, including cash handling and processing and change fund management, incorporating elements defined above, to be completed by December 1, 2022. (2) Management will evaluate organizational and staffing structure for effective and efficient processing of Athletics cash handling and depositing, while considering segregation of duties. As part of this process, management will formalize and document roles and responsibilities. Work to be completed by December 1, 2022. (3) The Whittemore Box Office safe combination will be changed by July 1, 2022. Management will maintain a list of staff with authorized access to the safe and safe combination. (4) Athletics management is working with UNH Finance to reduce the Whittemore safe change fund balance. As part of the reduction of the change fund balance, the variance in the change fund will be resolved with USNH FOC-Accounting Services. Work to be completed by July 1, 2022. (5) Training will be provided to staff responsible for handling, depositing, and recording of cash receipts by September 1, 2022.(6) Tamper-proof bags are now used by Athletics for the transportation of deposits to the bank or UNH Cashiers Office. (7) All interns/staff have to go through PCI certification and a background check before working in the Box Office. Athletics will validate and track that all student interns/staff are PCI certified and satisfied background checks prior to the start of 22/23 athletics season. (8) Athletics management will evaluate staffing and minimize cash operations to reduce risk through the use of automation and self-service options, including mobile tickets. (9) Athletics management is working with UNH Finance to identify vendor solutions to eliminate cash in Athletics 50/50 fundraising and parking operations. Work to be completed by July 1, 2022. (10) Athletics management will notify coaches and staff that commingling of personal funds with University funds is not allowed by September 1, 2022.(11) Management will reinforce existing USNH policy on adequate supporting documentation and ensure the policy is consistently applied to all cash receipt transactions. Work to be completed by December 1, 2022.



Perform key reconciliations

(1) Athletics management will work with Audience View to configure system for efficient and effective processing of ticket transactions, including allocation of ticket revenues to appropriate FOAPAL.(2) Management will develop procedures for periodic key reconciliations, including: Credit card transactions among Audience View, PayConex, bank account and Banner Finance Ticketing transactions among Audience View and Banner Finance Revenues transacted in software applications used to manage Athletics activities (Audience View, EMS, Destiny One, IModules, Red Card) to Banner Finance.(3) Management will reconcile FY22 revenue activity between sub-systems, PayConex, and Banner Finance.(4) Athletics worked with UNH Finance to develop a process to track revenue share contracts and associated payments. Contracts are reviewed on a periodic basis to ensure that revenue share payments are in accordance with contracts. (5) Athletics will evaluate opportunities to minimize manual cash activities and leverage technology and credit card options. Work to be completed by December 1, 2022.(6)Management will validate that credit card transaction funds were properly deposited in a USNH bank account. Management will work with USNH Treasury and FOC Accounting Services to identify ski/skate sale credit card transactions in Banner Finance and adjust allocation of transactions to appropriate FOAPAL.


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MGT. EXPLANATION & RESOLUTION PLAN @ 06/01/2022: (1) - (2) In process. Contracts+ has been moved to production and is in use by the Contracts team. New contracts are being stored in Contracts+, while current agreements are being added as time permits. The contract review and approval features are in production, however the implementation has been paused by competing UShop priorities. I anticipate this functionality will begin to be used in certain areas in late summer/early fall. The due date for the management action plan will be extended to September 30, 2022.

88 2020 USNH Contract Management

Reinforce existing USNH Procurement Policies and

Procedures

1) UShopNH is in the process of being released to campuses. All USNH procurement policies are incorporated into the application. A pilot group will start utilizing UShopNH in April 2020. In order to complete a purchase, campus staff are required to complete all steps. In addition, a reiteration of USNH procurement policies will be made via a System-wide communication and training opportunities. This will be completed by October 31, 2020. In addition, a link to Procurement policies will be made available on the USNH Procurement website and TeamDynamix induction page. This will be completed by October 31, 2020 - USNH Chief Procurement Officer2) UShopNH will soon become the central repository for USNH contracts. Additionally, the utilization of UShopNH should also decrease the number of contracts executed by USNH via consolidation of institutional contracts into system-wide contracts, increased utilization of consortium agreements, etc. Contract overlap / consolidation will be managed through a combination of reporting and strategic planning sessions with the Central USNH Procurement Organization and the impacted business users. The current plan is to implement the Jaggaer contracts module over the next several months with an initial focus on contracts related to the procurement of goods and services. In FY21, USNH plans to continue expansion of the Jaggaer contracts module to also include other contract types such as revenue contracts, lease agreements, etc.. This will be completed by June 30, 2021 - USNH Chief Procurement Officer

MGT. EXPLANATION & RESOLUTION PLAN @ 11/15/2021: (1) Resolved (2) In process. Contracts+ has been moved to production and is in use by the Contracts team. New contracts are being stored in Contracts+, while current agreements are being added as time permits. The contract review and approval features are in production, however the implementation has been paused by competing UShop priorities. I anticipate this functionality will begin to be used in certain areas in late summer/early fall.The release date on Contracts+ is also influenced by other factors such as the FOC restructure and UShop Shopper/Requisitioner training.The due date for the management action plan will be extended to September 30, 2022.


Enhance existing Standard Contracts

1) Revised general terms and conditions have been drafted which are being used to create a USNH Master Service Agreement (MSA) template. The revised MSA along with frequently used contract templates (ex. Consultant Agreements, Facilities Rental Agreement, ICA) will be made available for campus use as soon as possible. While the MSA template has been updated, a decision was made not to make it available to campuses until the Jaggaer contracts module has been implemented. This will be completed by June 30, 2021 - USNH Chief Procurement Officer2) The Jaggaer contracts module will provide contract drafting functionality and the standard USNH terms and conditions, etc. will be available for utilization by users. Non-USNH contracts will require a business justification and we anticipate a higher level of review and approval will be required for non-USNH contracts as they are deemed to be higher risk. This will be completed by June 30, 2021 - USNH Chief Procurement Officer


Enhance Protocols around Signature Authority

Administration

(1)Creating a new list of delegations within the Jaggaer contracts module with primary delegations to be provided to specific positions and automatically terminated when an employee leaves that position. This will be completed by June 30, 2021 - USNH Chief Procurement Officer(2)Once the updated delegation list is established, all existing delegations will be rescinded, and the new delegations immediately put in place. In addition, procedures will be developed to address changes to the list of delegations. This will be completed by June 30, 2021 - USNH Chief Procurement Officer(3) An annual review of the delegation list will be performed, adjustments made as needed, and the final list will be approved by the USNH Treasurer. This will be completed by June 30, 2021 - USNH Chief Procurement Officer(4) A recent decision has been made to implement the Jaggaer contracts module beginning in March 2020. As the technology will provide automated workflow approvals for contracts, we believe we will also be able to reduce the number of signature delegations that currently exist today. This will be completed by June 30, 2021 - USNH Chief Procurement Officer(5) As part of the current effort to update signature delegations, implement the Jaggaer contracts module, and establish a new business process, communication will be created and endorsed by the Treasurer, Procurement, and Campus CFO’s detailing the role of authorized signature delegates and that unauthorized contract signature will result in disciplinary action. This will be completed by June 30, 2021 - USNH Chief Procurement Officer

MGT. EXPLANATION & RESOLUTION PLAN @ 06/01/2022: (1) - (5) In process. Contracts+ has been moved to production and is in use by the Contracts team. New contracts are being stored in Contracts+, while current agreements are being added as time permits. The contract review and approval features are in production, however the implementation has been paused by competing UShop priorities. We anticipate this functionality will begin to be used in certain areas in late summer/early fall. The due date for the management action plan will be extended to September 30, 2022.

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Jan-21 Jan-22 Resolved 6/22

Jan-21 Jun-22 Resolved 6/22

92 2020 USNH Independent Contractor

91 2020 USNH Independent Contractor

Enhance protocols for independent contractor process

(1) The independent contractor policy, procedures and process will be reviewed and revised, outlining who owns each step in the process along with the risk associated, including the responsibility for compliance with IRS and DOL requirements.(2) USNH Procurement has updated its processes and shared information with the campuses. These procedures were documented and procreuemtn and end users were provided documentation and training as needed. These processes continue to evolve as new tools are identified. (3) Conflicts of interest will be evaluated based on Procurement Policy 6-001, Section C., Item 1, and USNH Personnel Policies, Section D, Item 7. Disagreements regarding non-approval of an independent contractor where there is a conflict, may be elevated to the campus VPFA for approval when they exceed $10,000. If Procurement disagrees with VPFA, Procurement may elevate to the VCFA at their discretion. (4) USNH Procurement will review the completed ICA form to ensure the ICA policy has been followed, which will be outlined in the new policy referenced above. (5) ICA document retention currently exists in Xtender and will be moved to USHOPNH.(6) Create annual dashboard/report for tracking and reporting of ICA in USHOPNH. Create the distribution list for the report and the owner of the creation of the report.

MGT. EXPLANATION & RESOLUTION PLAN @ 6/2/22: (1) New ICA processes and workflows were developed and documented. ICAs are now centrally managed by Procurement Operations and the Independent Contractor Agreement is reviewed and signed by Procurement Authority. Formalized training on new processes is expected to be completed by July 29, 2022. (2) In addition, USNH Procurement created an Independent Contractor checklist guidance document and has shared this document across USNH. (3) Upon completion of the ICA if a relationship is disclosed, Procurement has the requestor complete a form disclosing the relationship. The form is reviewed and approved prior to approving the ICA. (4) Procurement Operations staff review the ICA for consistency and accuracy. The ICAs are reviewed and approved by the Director of Procurement Operations. (5) Jaggaer Contracts Plus was adopted for storage and retention of the ICAs as of April 2022. (6) Contracts Plus search and reporting functionality is available within the system. Administrators and contract stakeholders have acccess to search and run reports.

MGT. EXPLANATION & RESOLUTION PLAN @ 6/2/22: New ICA processes and workflows were developed and documented. ICAs are now centrally managed by Procurement Operations and the Independent Contractor Agreement is reviewed and signed by Procurement Authority. The Procurement Operations Team and Director are responsible for reviewing, ensuring compliance, and approving Independent Contractors.

The independent contractor policy, procedures and process will be reviewed and revised, outlining who owns each step in the process along with the risk associated, including the responsibility for compliance with IRS and DOL requirements. This work will be completed by January 1, 2021.

Lack of formal ownership for independent contractor process

2020 USNH Contract Management

Enhance process around Contract Review

1) An updated contract checklist, including the review of appropriate stakeholders, has been created and will be made available to users in TeamDynamix, and on the USNH Procurement website. This will be completed by October 31, 2020 - USNH Chief Procurement Officer2) The checklist is incorporated within UShopNH once the Jaggaer contracts module is available. The checklist will address areas of due diligence, disclosure of existing or potential conflicts of interest, etc. This will be completed by June 30, 2021 - USNH Chief Procurement Officer3) USNH will provide communications and training as needed regarding the use of the Jaggaer contracts module. This will be completed by June 30, 2021 - USNH Chief Procurement Officer4) Once implemented, policies and procedures will be established to collect all procurement-related contracts within UShopNH. This will be completed by June 30, 2021 - USNH Chief Procurement Officer5) USNH has an independent contractor determination checklist which will be revised to include a signature from the hiring administrator and human resources. This will be completed by October 31, 2020 - USNH Chief Procurement Officer

90 2020 USNH Duplicate Payments

(1) USNH Financial Services validated the duplicate payments and will work with campuses to recover funds from the vendor or apply the overpayment to future vendor invoices, as necessary. We will have this completed by June 30, 2020.(2) UNSH Financial Services will incorporate a monthly review of continuous monitoring reports for duplicate payments to begin by June 30, 2020.

MGT. EXPLANATION & RESOLUTION PLAN @ 5/31/22: (1) In process; USNH has collected some of the duplicate payments identified and is working on additional follow-up. Revised due date of September 30, 2022. (2) Resolved

Enhance controls over entry and payment of vendor invoices

MGT. EXPLANATION & RESOLUTION PLAN @ 11/15/2021: (1) - 5) In process. The Independent Contractor Agreement has been revised to included a hiring admin signature.USNH Procurement is working on the development of ICA policy, procedures, and process. Contracts+ has been moved to production and is in use by the Contracts team. New contracts are being stored in Contracts+, while current agreements are being added as time permits. The contract review and approval features are in production, however the implementation has been paused by competing UShop priorities. We anticipate this functionality will begin to be used in certain areas in late summer/early fall.The release date on Contracts+ is also influenced by other factors such as the FOC restructure and UShop Shopper/Requisitioner training.The due date for the management action plan will be extended to September 30, 2022.

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