Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: No
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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.
Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review.
Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review.
Questioned costs: N/A
Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation.
Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University.
Repeat finding: No
Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term.
Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change.
Questioned costs: N/A
Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term.
Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting.
Repeat finding: No
Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University did not have a formal review process related to GLBA.
Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment.
Questioned costs: N/A
Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process.
Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs.
Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report.
Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398.
Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report.
Questioned costs: N/A
Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review.
Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency.
Repeat finding: No
Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F
Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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.
Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures.
Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: No
Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.