2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 3 students out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus and program level records in the NSLDS and 1 student out of a sample of 40 was reported to the NSLDS with the incorrect enrollment effective date on the program level records only. Cause: The University was not using the last day of attendance as the students? effective date of the status change when reporting to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 3 students out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus and program level records in the NSLDS and 1 student out of a sample of 40 was reported to the NSLDS with the incorrect enrollment effective date on the program level records only. Cause: The University was not using the last day of attendance as the students? effective date of the status change when reporting to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-003 ? Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing number: 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution must reconcile the institutional records with the Direct Loan funds received from ED as well as to the Direct Loan disbursement records submitted to and accepted by ED (34 CFR 685.300(b)(5)). Condition: During our testing it was noted that a direct loan reconciliation was not completed on a timely basis. Questioned costs: None. Context: During our testing, we noted 1 out of 3 monthly reconciliations selected was not completed on a timely basis. Cause: The University experienced turnover and the reconciliation was not completed on a timely basis. Effect: The University did not comply with its internal policy and federal requirements to ensure funds are properly reconciled monthly. Repeat Finding: No. Auditors? Recommendation: The University should ensure employees receive proper training, support, and time to follow the University?s policies and federal requirements related to monthly reconciliations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-004 ? Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing number: 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 requires entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who cease at least half-time study at the school. Condition: Exit counseling was not completed. Questioned costs: None. Context: During our testing, we noted 1 student out of a sample of 40 tested where the University failed to notify the student to complete exit counseling. Cause: The University?s process and controls did not ensure that the student was notified, and that proper support was maintained to document the process took place. Effect: A student did not receive the proper loan counseling which may contribute to a higher default rate. Repeat Finding: No. Auditors? Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 005 ? Suspension and Debarment Policy Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal assistance listing number: 84.425F Award period: 7/1/21-6/30/22 Type of finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University has implemented formal, written policies and procedures to align with the requirements for suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 3 transactions for suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s suspension and debarment policies. Cause: The University did not maintain documentation to support this process was performed. Effect: Supporting documentation could not be located to support required suspension and debarment standards were followed. Repeat Finding: No. Auditors? Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 3 students out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus and program level records in the NSLDS and 1 student out of a sample of 40 was reported to the NSLDS with the incorrect enrollment effective date on the program level records only. Cause: The University was not using the last day of attendance as the students? effective date of the status change when reporting to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 3 students out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus and program level records in the NSLDS and 1 student out of a sample of 40 was reported to the NSLDS with the incorrect enrollment effective date on the program level records only. Cause: The University was not using the last day of attendance as the students? effective date of the status change when reporting to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-003 ? Direct Loan Reconciliations Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing number: 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution must reconcile the institutional records with the Direct Loan funds received from ED as well as to the Direct Loan disbursement records submitted to and accepted by ED (34 CFR 685.300(b)(5)). Condition: During our testing it was noted that a direct loan reconciliation was not completed on a timely basis. Questioned costs: None. Context: During our testing, we noted 1 out of 3 monthly reconciliations selected was not completed on a timely basis. Cause: The University experienced turnover and the reconciliation was not completed on a timely basis. Effect: The University did not comply with its internal policy and federal requirements to ensure funds are properly reconciled monthly. Repeat Finding: No. Auditors? Recommendation: The University should ensure employees receive proper training, support, and time to follow the University?s policies and federal requirements related to monthly reconciliations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022-004 ? Exit Counseling Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing number: 84.268 Award period: 7/1/2021 ? 6/30/2022 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 requires entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who cease at least half-time study at the school. Condition: Exit counseling was not completed. Questioned costs: None. Context: During our testing, we noted 1 student out of a sample of 40 tested where the University failed to notify the student to complete exit counseling. Cause: The University?s process and controls did not ensure that the student was notified, and that proper support was maintained to document the process took place. Effect: A student did not receive the proper loan counseling which may contribute to a higher default rate. Repeat Finding: No. Auditors? Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 005 ? Suspension and Debarment Policy Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal assistance listing number: 84.425F Award period: 7/1/21-6/30/22 Type of finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University has implemented formal, written policies and procedures to align with the requirements for suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 3 transactions for suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s suspension and debarment policies. Cause: The University did not maintain documentation to support this process was performed. Effect: Supporting documentation could not be located to support required suspension and debarment standards were followed. Repeat Finding: No. Auditors? Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.