Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Title III, ALN #84.031B
Criteria: The Title III grant requires a match for endowment funding.
Condition: The required match did not occur during the fiscal year.
Context: During the fiscal year 2021 a contribution was recorded to the endowment for $200,000. This was an allowable expenditure under the grant agreement. However, a match of $200,000 was required, and the match was not made during fiscal year 2021 or fiscal year 2022. During the current year, there was no match made to the endowment.
Questioned Cost: None
Effect: The University was not in compliance with the grant agreement.
Cause: The University did not follow up and make the transfer from local funds.
Repeat Finding: Yes
Recommendation: We recommend that when the original grant expenditure is recorded, that the grant match occurs at the same time.
Response: We agree with the intent of this finding but not the dollar amounts.
The contribution of $100,000 was received via Title III and Central State matched the $100,000. The total of both amounts is $200,000. Central State matches with $100,000.
We did have a time lag for execution of the check and transfer to the endowment. The controller’s office will establish the protocol of being timely in matching the payment and in depositing the funds in the appropriate investment account.
Responsible Person: Controller (Trasenna Gray)
Completion Date: January 2024 and ongoing
Auditor Response: The documentation provided shows that the endowment was funded $200,000 from federal funds during fiscal year 2021 and there has been no supporting documentation provided to show any funds related to a match. The $200,000 was included in the schedule of federal expenditures in fiscal year 2021 and was requested for reimbursement from federal funds.
Federal Program Information: Title III, ALN #84.031B
Criteria: Title III costs claimed as expenses need to have the underlying activity within the fiscal year.
Condition: Expenses that were for a time period longer than the fiscal year were fully expensed and claimed in the current year.
Context: 7 of 60 expenses tested were for a time period that was longer than the current fiscal year. The entire amount of the invoice, including the portion outside of the fiscal year was expensed and claimed in the current year.
Questioned Cost: $42,375
Effect: Expenses for the current year were overstated.
Cause: The University did not adjust grant expenses for an adjustment to prepaid amounts.
Repeat Finding: No
Recommendation: We recommend that expenses be reviewed for recording in the proper period when the invoice is received.
Response: Views of responsible officials: Curtis Pettis
Completion Date: Finding Challenged
The University concurs with the finding. The University will put procedures in place within the Accounts Payable department to identify invoice payments which impact expenses beyond the current Fiscal Year. The University Controller will use this information to ensure the prepaid entries are completed as part of the monthly closing process.
Responsible Person: Controller (Trasenna Gray)
Completion Date: January 2024
Federal Program Information: Federal Direct Loan Program, ALN #84.268
Criteria: 34 CFR 685.203, Loan Limits
Condition: Federal Direct Loans were incorrectly awarded and disbursed to students.
Context: Three students incorrectly received unsubsidized loans based on independent limits instead of dependent limits.
Questioned Cost: $9,250
Effect: Students were incorrectly awarded and disbursed student financial aid.
Cause: Errors in management's packaging of the student financial aid resulted in inaccurate awards and disbursements to students.
Repeat Finding: No
Recommendation: We recommend implementing procedures that appropriately determines student financial aid to students and ensures the proper disbursements.
Response: There is a myriad of activities and timing issues that can impact awards and ultimate disbursements. In some cases, the dependency status can change as FAFSA and corresponding loan forms are revised.
The Financial Aid department is committed to review internal processes and system rules to ensure that the Banner packaging process is set up to catch changes in dependency status and awards accordingly.
Responsible Person: Director of Financial Aid (Mitch Dedor)
Completion Date: December 2023
Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007
Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds.
Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term.
Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year.
b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year.
c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement.
d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them.
Questioned Cost: Unknown
Effect: Errors were made during the calculations, support was not maintained and calculations were not performed.
Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022.
Repeat Finding: Yes
Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations.
Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area.
Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci)
Completion Date: December 2023
Federal Program Information: Title III, ALN #84.031B
Criteria: The Title III grant requires a match for endowment funding.
Condition: The required match did not occur during the fiscal year.
Context: During the fiscal year 2021 a contribution was recorded to the endowment for $200,000. This was an allowable expenditure under the grant agreement. However, a match of $200,000 was required, and the match was not made during fiscal year 2021 or fiscal year 2022. During the current year, there was no match made to the endowment.
Questioned Cost: None
Effect: The University was not in compliance with the grant agreement.
Cause: The University did not follow up and make the transfer from local funds.
Repeat Finding: Yes
Recommendation: We recommend that when the original grant expenditure is recorded, that the grant match occurs at the same time.
Response: We agree with the intent of this finding but not the dollar amounts.
The contribution of $100,000 was received via Title III and Central State matched the $100,000. The total of both amounts is $200,000. Central State matches with $100,000.
We did have a time lag for execution of the check and transfer to the endowment. The controller’s office will establish the protocol of being timely in matching the payment and in depositing the funds in the appropriate investment account.
Responsible Person: Controller (Trasenna Gray)
Completion Date: January 2024 and ongoing
Auditor Response: The documentation provided shows that the endowment was funded $200,000 from federal funds during fiscal year 2021 and there has been no supporting documentation provided to show any funds related to a match. The $200,000 was included in the schedule of federal expenditures in fiscal year 2021 and was requested for reimbursement from federal funds.
Federal Program Information: Title III, ALN #84.031B
Criteria: Title III costs claimed as expenses need to have the underlying activity within the fiscal year.
Condition: Expenses that were for a time period longer than the fiscal year were fully expensed and claimed in the current year.
Context: 7 of 60 expenses tested were for a time period that was longer than the current fiscal year. The entire amount of the invoice, including the portion outside of the fiscal year was expensed and claimed in the current year.
Questioned Cost: $42,375
Effect: Expenses for the current year were overstated.
Cause: The University did not adjust grant expenses for an adjustment to prepaid amounts.
Repeat Finding: No
Recommendation: We recommend that expenses be reviewed for recording in the proper period when the invoice is received.
Response: Views of responsible officials: Curtis Pettis
Completion Date: Finding Challenged
The University concurs with the finding. The University will put procedures in place within the Accounts Payable department to identify invoice payments which impact expenses beyond the current Fiscal Year. The University Controller will use this information to ensure the prepaid entries are completed as part of the monthly closing process.
Responsible Person: Controller (Trasenna Gray)
Completion Date: January 2024
Federal Program Information: Federal Direct Loan Program, ALN #84.268
Criteria: 34 CFR 685.203, Loan Limits
Condition: Federal Direct Loans were incorrectly awarded and disbursed to students.
Context: Three students incorrectly received unsubsidized loans based on independent limits instead of dependent limits.
Questioned Cost: $9,250
Effect: Students were incorrectly awarded and disbursed student financial aid.
Cause: Errors in management's packaging of the student financial aid resulted in inaccurate awards and disbursements to students.
Repeat Finding: No
Recommendation: We recommend implementing procedures that appropriately determines student financial aid to students and ensures the proper disbursements.
Response: There is a myriad of activities and timing issues that can impact awards and ultimate disbursements. In some cases, the dependency status can change as FAFSA and corresponding loan forms are revised.
The Financial Aid department is committed to review internal processes and system rules to ensure that the Banner packaging process is set up to catch changes in dependency status and awards accordingly.
Responsible Person: Director of Financial Aid (Mitch Dedor)
Completion Date: December 2023