Audit 12556

Finding No: 2023-001 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 Program: COVID -19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: January 1, 2020 through December 31, 2022 (a) Criteria or Requirement The specific requirements for activities allowed or unallowed are unique to each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. This program allows expenditures to prevent, prepare for, and respond to coronavirus and COVID-19, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work, we selected a sample of 60 non-payroll disbursements made during the fiscal year 2023 reporting period. We noted eight instances totaling $1,717 in which expenditures were approved for payment based on vendor invoices which included inaccurate calculations. In addition, we noted three instances of duplicate expenditures totaling $38,971 being transferred and charged to the program. Lastly, the University was unable to provide supporting documentation and evidence of the effective operation of the management review control for one of the 60 disbursements sampled totaling $803. (c) Possible Cause The University has a management review process to review invoices and related documentation before payments are disbursed. The University management review control that was in place did not operate effectively to prevent duplicate charges, inaccurate amounts and charges that lacked supporting documentation from being submitted for reimbursement by the federal agency. (d) Questioned Cost Duplicate expenditures totaling $38,971 and payment of inaccurate vendor invoices totaling $1,717. (e) Effect Federal funds were expended for duplicated or inaccurate amounts and supporting documentation and evidence of the effective operation of management review controls were not consistently maintained in accordance with Federal requirements. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding also occurred in the prior year listed as Finding No. 2022-001. (h) Recommendation We recommend that the University strengthen controls over the management review process to prevent duplicate and inaccurate amounts from being charged to Federal programs and to enhance the retention of supporting documentation and evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While appropriate controls exist relative to management review and recalculation of expenditures, opportunities exist to retrain staff and further enhance controls related to procedures for submission, review, and approval of contract labor invoices. Specific instructions to recalculate each contract employees’ timesheet(s) and agree the totals to the related invoice prior to approval were distributed and outlined for department managers, accountants, and accounts payable staff. In addition, the process for reviewing and approving grant expenditures has since been enhanced subsequent to manager turnover during the fiscal year. Specifically, employees responsible for processing grant transfer documentation will ensure documents contain management approval(s), grants and contracts accounting approval, and appropriate documentation prior to keying and uploading documentation into the general ledger. The new practice will help compensate for employee turnover as documentation of historical review will be available to successors.

Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.

Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.

Finding No: 2023-001 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 Program: COVID -19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: January 1, 2020 through December 31, 2022 (a) Criteria or Requirement The specific requirements for activities allowed or unallowed are unique to each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. This program allows expenditures to prevent, prepare for, and respond to coronavirus and COVID-19, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work, we selected a sample of 60 non-payroll disbursements made during the fiscal year 2023 reporting period. We noted eight instances totaling $1,717 in which expenditures were approved for payment based on vendor invoices which included inaccurate calculations. In addition, we noted three instances of duplicate expenditures totaling $38,971 being transferred and charged to the program. Lastly, the University was unable to provide supporting documentation and evidence of the effective operation of the management review control for one of the 60 disbursements sampled totaling $803. (c) Possible Cause The University has a management review process to review invoices and related documentation before payments are disbursed. The University management review control that was in place did not operate effectively to prevent duplicate charges, inaccurate amounts and charges that lacked supporting documentation from being submitted for reimbursement by the federal agency. (d) Questioned Cost Duplicate expenditures totaling $38,971 and payment of inaccurate vendor invoices totaling $1,717. (e) Effect Federal funds were expended for duplicated or inaccurate amounts and supporting documentation and evidence of the effective operation of management review controls were not consistently maintained in accordance with Federal requirements. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding also occurred in the prior year listed as Finding No. 2022-001. (h) Recommendation We recommend that the University strengthen controls over the management review process to prevent duplicate and inaccurate amounts from being charged to Federal programs and to enhance the retention of supporting documentation and evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While appropriate controls exist relative to management review and recalculation of expenditures, opportunities exist to retrain staff and further enhance controls related to procedures for submission, review, and approval of contract labor invoices. Specific instructions to recalculate each contract employees’ timesheet(s) and agree the totals to the related invoice prior to approval were distributed and outlined for department managers, accountants, and accounts payable staff. In addition, the process for reviewing and approving grant expenditures has since been enhanced subsequent to manager turnover during the fiscal year. Specifically, employees responsible for processing grant transfer documentation will ensure documents contain management approval(s), grants and contracts accounting approval, and appropriate documentation prior to keying and uploading documentation into the general ledger. The new practice will help compensate for employee turnover as documentation of historical review will be available to successors.

Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.

Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.