2022-006 ? Quarterly Higher Education Emergency Relief Fund (HEERF) Reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion and COVID-19 HEERF Supplemental Assistance to Institutions of Higher Education (SAIHE) Program Award Numbers: P425F202269 and P425S210019 Assistance Listing Titles: COVID-19 HEERF Student Portion and COVID-19 HEERF SAIHE Program Assistance Listing Number: 84.425E and 84.425S Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The quarterly HEERF reporting format requires institutions to report the total amount of HEERF (a)(1) Student Aid disbursed directly to students as Emergency Financial Aid Grants along with other information. (a)(1) is equivalent to funds disbursed under Assistance Listing #84.425E. SAIHE funds are considered (a)(3) funds and are required to be reported in a separate section of the quarterly HEERF report. Reports are required to be posted to an institution's website 10 days after each calendar quarter end. Condition Through our testing of 14 quarterly student and institutional reports across 4 campuses, we noted the following at 1 campus : ? Through our testing, we reconciled the total cumulative student spending as reported on the June 30, 2022 quarterly report to the total cumulative spending of the student portion at this campus and noted that total student funds reported were $1,505,755 in excess of the cumulative awards actually spent. This variance represented 50% of this campus?s award under 84.425S, which was awarded to students, however, this should not have been included in the 84.425E totals. ? The June 30, 2022 quarterly report was also submitted 2 days late. Cause Management did not realize that 84.425S funds awarded to students should not be commingled in the quarterly reports with the 84.425E student portion spending. Additionally, the due date of the report was a Sunday and instead of recognizing the report should be submitted the next business day or prior, it was submitted 2 days late. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None noted. Recommendation We recommend management amend their June 30, 2022 report to include the correct amounts and assess whether any other quarters are impacted. Additionally, they should implement a control to review proper classification of funds in future quarterly reports and to ensure timely submission. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-005 ? HEERF Institutional portion unallowable costs Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) II and III Institutional Portions Award Numbers: P425F202269 and P425F201852 - 20A Assistance Listing Title: COVID-19 HEERF Institutional Portion Assistance Listing Number: 84.425F Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The Department of Education Certification and Agreement for both HEERF II and HEERF III notes that recipients may use these grant funds for Institutional costs to defray expenses associated with COVID-19 (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll), and make additional emergency financial grants to students, which may be used for any component of the student?s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care), or child care. Cost of attendance, as defined under section 472 of the Higher Education Act, includes food, housing, course materials, technology, health care, and child-care. Condition Through our testing of 75 institutional portion costs across 3 campuses, we noted the following at 2 campuses: ? 1 out of 25 selections tested at one campus related to $250 scholarships awarded to 19 students totaling $4,750 for summer 2021. These scholarships were awarded to students participating in an early start academy to help the student prepare for future academic success. Criteria to qualify for the scholarships included earning a 2.5 GPA or higher, passing HESA 001, completing/turning in an education plan and attending 4 academic support sessions at the Academic Resource Center. This scholarship program was not related to awarding funds to students for emergency costs arising due to COVID-19 or for elements of the cost of attendance, as defined in the criteria above. In total, $58,000 in awards were made to students under this scholarship program in fiscal year 2022, which were not allowable costs per HEERF guidelines . ? At a second campus, we performed testing over $21,803,672 claimed in lost revenue, which was supported in part by $6,103,672 of lost rental revenue. Through our testing of individual leases making up the lost rental revenue, we noted : o 1 lease arrangement totaling $1,345,330 was selected for testing and management noted that this lease should have been excluded from the analysis. It was included in an initial analysis as reflecting potential lost revenue, but lost revenue was not ultimately realized and this lease was not appropriately removed in the final lost revenue analysis. o 1 lease in which the supporting spreadsheet calculation of lost revenue was incorrect. This lease had different terms than others in the spreadsheet, but lost revenue was calculated as if the terms were consistent with the other leases, resulting in an overstatement of lost revenue of $39,000. ? Additionally, at the second campus, for each of our 7 fringe benefit selections, totaling $19,581 we were unable to obtain support for the 52% fringe benefits rate used to derive the amount charged to the award. We were able to see approved hours worked on the award and support for the employee pay rates, however, the 52% rate used to derive the fringe benefits charged could not be provided by management. Cause ? In the first instance, the use of these funds went through all appropriate approval levels, including the Provost and Chancellor, however, there was a lack of understanding that this scholarship program did not meet the HEERF III criteria noted above. ? In the second instance, the impacted campus has a significant amount of leases and the process for tracking the leases, lease amendments due to COVID-19 and the associated lost revenue analysis was manual. There also was no formal evidence of review of this analysis prior to it being provided to central campus finance management. ? In the third instance, management could not locate the support for the rate used due to not maintaining complete internal records. Effect Given the nature of the expenses above, they were not eligible for reimbursement under HEERF and resulted in questioned costs. Questioned Costs $1,461,911 Recommendation We recommend management at the first campus review any future scholarship programs being funded with HEERF institutional funds to ensure they meet the criteria laid out in the HEERF certification and agreement. We recommend that management at the second campus review their lease tracking and management process and formalize controls over the review of future lost revenue analyses. Additionally, they should ensure support for all costs charged to the HEERF award can be fully supported, including support for the fringe benefits rate being charged. Additionally, in both of these scenarios, management should reverse these transactions, update quarterly HEERF reports, as needed, and determine if the funds can be used for other allowable purposes and/or return the funds to the federal government. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings. ay rates, however, the 52% rate used to derive the fringe benefits charged could not be provided by management.
2022-007 ? HEERF Procurement, Suspension and Debarment Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: P425F202269 Assistance Listing Title: COVID-19 HEERF Institutional Portion Assistance Listing Number: 84.425F Award Year: 2020-2022 Pass-through entity: Not applicable Criteria A non-Federal entity must have and use documented procurement procedures and is 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 with an entity at a lower tier, 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Through our testing of 12 selections across 3 campuses (out of a population of 54 across all 3 campuses) for both procurement and suspension and debarment, we noted the following for 2 out of 3 transactions selected for testing at 1 campus : ? Missing original Source Selection & Price Reasonableness justification forms demonstrating appropriate procurement decisions and approval took place prior to the transactions, which are required at this campus for transactions greater than $10,000. ? Management could not provide evidence that suspension and debarment checks were performed prior to purchase. We received evidence of the checks after the purchase. Cause Management indicated that the Source Selection & Price Reasonableness justification forms and the suspension and debarment checks were performed, however, they misplaced the original documentation. Effect The University may not follow appropriate procurement policies and procedures and may inappropriately do business with a vendor that is suspended or debarred if timely checks are not performed. Questioned Costs None noted. Recommendation We recommend that management reassess their document retention protocols and ensure controls are in place to ensure complete and accurate files, inclusive of timely suspension and debarment checks. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-008 ? Completeness and accuracy of certain COVID-19 programs on the Prior Year Schedule of Expenditures of Federal Awards (SEFA) - (Significant Deficiency) Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services (HHS) - Health Resources and Services Administration (HRSA) and Department of Education Award Names: COVID-19 Provider Relief Fund (PRF) and COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: Not applicable and P425F202269 Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution and COVID-19 HEERF Institutional Portion Assistance Listing Number: 93.498 and 84.425F Award Year: 2020-2021 and 2020-2022 Pass-through entity: Not applicable Criteria 2 CFR 200.510 Financial statements requires auditees to prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records and other federal guidance. Condition The following errors were identified in the University?s 2021 SEFA: ? Management at the University Office of the President brought to our attention that in the prior year, the PRF Period 1 expenditures at 1 hospital that was part of a certain medical center with multiple portal submissions, was not included on the University?s SEFA. This error totaled $26,358,874 and represented 6% of total Period 1 PRF expenditures included on the SEFA and 0.4% of the University?s total SEFA. Exclusion of this amount did not impact the major program determination in 2021 or our scoping of the PRF major program across the University as a whole. Management has included this amount on the 2022 SEFA. ? Through our discussions with management at a second campus, we identified 2 additional PRF portal submissions were excluded from the 2021 SEFA, as follows: Period 1 $473,339 and Period 1 $11,962. These submissions have also been included in the 2022 SEFA. ? Through our current year testing at a third campus, we noted that the 2021 HEERF institutional funds expended per management?s analysis did not agree to the amount reported on the 2021 SEFA. The amount reported in the prior year was understated by $1,296,498. This amount was not material to HEERF or to the 2021 SEFA as a whole. This amount has also been included in the 2022 SEFA. Cause The COVID-19 pandemic resulted in the receipt and expenditure of federal funds across certain University medical centers where there has previously been limited to no federal funding and a different nature of funding at certain of the campuses. The preparation of the SEFA requires information from each campus be provided to the University Office of the President for compilation, and the aggregation of the COVID-19 PRF funding was manual. In addition, there was limited knowledge of the federal funding at the medical centers and thus a reliance on the part of management that each campus was reporting complete and accurate information. A final reconciliation of all portal submissions compared to the amounts on the SEFA also failed to detect the missing PRF expenditures at this one medical center. Additionally, regarding the HEERF missing amounts, the correct amount was communicated by the campus to the University Office of the President, however, this communication was overlooked by the preparer of the SEFA, since a manual adjustment was required. Effect A SEFA that is not complete and accurate could impact the scoping of an entity?s major programs and result in incomplete information being provided to the federal government. Questioned Costs None noted. Recommendation We recommend updates on atypical federal programs (e.g., HEERF and PRF) at each campus (including the medical centers) be periodically provided to the team at the University Office of the President that is responsible for the compilation of the SEFA. This will allow for a more comprehensive understanding of the campus grant activity for these programs and the ability to better review and assess the completeness and accuracy reported for these programs on the University?s year-end SEFA, inclusive of these programs. One means by which this might be accomplished is to develop a checklist of anticipated awards by campus in advance of the year and also complete an interim SEFA to identify inconsistencies earlier in the fiscal year. We recommend the campuses review the interim SEFA for completeness and accuracy and provide a formal sign-off/approval to the University Office of the President. We also recommend formal review of the final year-end SEFA be evidenced by the Systemwide Controller or other appropriate personnel. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-006 ? Quarterly Higher Education Emergency Relief Fund (HEERF) Reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion and COVID-19 HEERF Supplemental Assistance to Institutions of Higher Education (SAIHE) Program Award Numbers: P425F202269 and P425S210019 Assistance Listing Titles: COVID-19 HEERF Student Portion and COVID-19 HEERF SAIHE Program Assistance Listing Number: 84.425E and 84.425S Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The quarterly HEERF reporting format requires institutions to report the total amount of HEERF (a)(1) Student Aid disbursed directly to students as Emergency Financial Aid Grants along with other information. (a)(1) is equivalent to funds disbursed under Assistance Listing #84.425E. SAIHE funds are considered (a)(3) funds and are required to be reported in a separate section of the quarterly HEERF report. Reports are required to be posted to an institution's website 10 days after each calendar quarter end. Condition Through our testing of 14 quarterly student and institutional reports across 4 campuses, we noted the following at 1 campus : ? Through our testing, we reconciled the total cumulative student spending as reported on the June 30, 2022 quarterly report to the total cumulative spending of the student portion at this campus and noted that total student funds reported were $1,505,755 in excess of the cumulative awards actually spent. This variance represented 50% of this campus?s award under 84.425S, which was awarded to students, however, this should not have been included in the 84.425E totals. ? The June 30, 2022 quarterly report was also submitted 2 days late. Cause Management did not realize that 84.425S funds awarded to students should not be commingled in the quarterly reports with the 84.425E student portion spending. Additionally, the due date of the report was a Sunday and instead of recognizing the report should be submitted the next business day or prior, it was submitted 2 days late. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None noted. Recommendation We recommend management amend their June 30, 2022 report to include the correct amounts and assess whether any other quarters are impacted. Additionally, they should implement a control to review proper classification of funds in future quarterly reports and to ensure timely submission. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-008 ? Completeness and accuracy of certain COVID-19 programs on the Prior Year Schedule of Expenditures of Federal Awards (SEFA) - (Significant Deficiency) Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services (HHS) - Health Resources and Services Administration (HRSA) and Department of Education Award Names: COVID-19 Provider Relief Fund (PRF) and COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: Not applicable and P425F202269 Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution and COVID-19 HEERF Institutional Portion Assistance Listing Number: 93.498 and 84.425F Award Year: 2020-2021 and 2020-2022 Pass-through entity: Not applicable Criteria 2 CFR 200.510 Financial statements requires auditees to prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records and other federal guidance. Condition The following errors were identified in the University?s 2021 SEFA: ? Management at the University Office of the President brought to our attention that in the prior year, the PRF Period 1 expenditures at 1 hospital that was part of a certain medical center with multiple portal submissions, was not included on the University?s SEFA. This error totaled $26,358,874 and represented 6% of total Period 1 PRF expenditures included on the SEFA and 0.4% of the University?s total SEFA. Exclusion of this amount did not impact the major program determination in 2021 or our scoping of the PRF major program across the University as a whole. Management has included this amount on the 2022 SEFA. ? Through our discussions with management at a second campus, we identified 2 additional PRF portal submissions were excluded from the 2021 SEFA, as follows: Period 1 $473,339 and Period 1 $11,962. These submissions have also been included in the 2022 SEFA. ? Through our current year testing at a third campus, we noted that the 2021 HEERF institutional funds expended per management?s analysis did not agree to the amount reported on the 2021 SEFA. The amount reported in the prior year was understated by $1,296,498. This amount was not material to HEERF or to the 2021 SEFA as a whole. This amount has also been included in the 2022 SEFA. Cause The COVID-19 pandemic resulted in the receipt and expenditure of federal funds across certain University medical centers where there has previously been limited to no federal funding and a different nature of funding at certain of the campuses. The preparation of the SEFA requires information from each campus be provided to the University Office of the President for compilation, and the aggregation of the COVID-19 PRF funding was manual. In addition, there was limited knowledge of the federal funding at the medical centers and thus a reliance on the part of management that each campus was reporting complete and accurate information. A final reconciliation of all portal submissions compared to the amounts on the SEFA also failed to detect the missing PRF expenditures at this one medical center. Additionally, regarding the HEERF missing amounts, the correct amount was communicated by the campus to the University Office of the President, however, this communication was overlooked by the preparer of the SEFA, since a manual adjustment was required. Effect A SEFA that is not complete and accurate could impact the scoping of an entity?s major programs and result in incomplete information being provided to the federal government. Questioned Costs None noted. Recommendation We recommend updates on atypical federal programs (e.g., HEERF and PRF) at each campus (including the medical centers) be periodically provided to the team at the University Office of the President that is responsible for the compilation of the SEFA. This will allow for a more comprehensive understanding of the campus grant activity for these programs and the ability to better review and assess the completeness and accuracy reported for these programs on the University?s year-end SEFA, inclusive of these programs. One means by which this might be accomplished is to develop a checklist of anticipated awards by campus in advance of the year and also complete an interim SEFA to identify inconsistencies earlier in the fiscal year. We recommend the campuses review the interim SEFA for completeness and accuracy and provide a formal sign-off/approval to the University Office of the President. We also recommend formal review of the final year-end SEFA be evidenced by the Systemwide Controller or other appropriate personnel. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and Iraq and Afghanistan Service Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution on the advance method follows up with a disbursement record for that student no earlier than 7 calendar days prior to the disbursement date under the advance or heightened cash monitoring payment methods. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. The Compliance Supplement notes that the key items for an auditor to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when applicable), transaction number, cost of attendance, and academic calendar. Key items to test on disbursement records are disbursement date and amount. Condition Through our testing of 100 selections across 4 campuses, we noted at one campus that the date of disbursement per the COD did not match the date per the student account detail for 12 out of 25 selections. Additionally, 5 of the 25 selections were not reported to the COD within 15 calendar days of the disbursement to the student. On average, the 5 disbursements were reported 9 calendar days late. Lastly, for one selection, a student was reported into the COD 8 days before the disbursement, which is 1 day earlier than permitted by the regulation . Cause Through discussions with management, they noted that the errors and late/early reporting were due to staffing and training issues, as they continue to be challenged with staff retention and recruitment. Effect Inaccurate information within the COD system could lead to inaccurate information in reports utilized by the Department of Education. Questioned Costs None noted. Recommendation We recommend the campus provide additional training on COD reporting requirements, including on the disbursement dates that should be reported and the timeline for reporting and that additional reviews be considered to identify potential errors prior to submission into the COD. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis Direct Loan, 34 CFR section 685.309. Condition Through our testing of 100 enrollment reporting selections across 4 campuses, we noted the following at 2 campuses: ? For 3 of 25 selections at one campus, we noted that the effective date of the change per NSLDS did not agree to the effective date of the actual status change per the student file. In each of these instances, the student was changing from part-time to full-time . ? For 4 of 25 selections at a third campus, we noted that the students were reported as withdrawn when they should have been reported as graduated . Our understanding in each of the scenarios above, is that there would be no impact on repayment dates for students with loans, and thus these errors do not result in questioned costs or have an impact to the student or federal government. Cause ? The cause of the reporting finding at the first campus is that there was a system error that was backdating the campus-level enrollment effective date to the first date of the term when a student increased attendance, which is why the effective date per NSLDS did not agree to the effective date in the student file. ? Regarding the second campus, this finding relates to the sequence of reporting enrollment changes during the summer, and ultimately has a broader impact going back several years. During the summer, management noted they correctly reported graduated status more than once. However, in their final summer enrollment file, the status for these students was noted to be full-time status, which was true, but this full-time status overwrote their previously reported graduated status. Under standard practice, when these students did not appear in the fall enrollment file, the National Student Clearinghouse derived a withdrawn status, which was reported to NSLDS. There were also various error reports for which this campus was behind on fully resolving, resulting in this issue not being identified by management Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure COD error reports are resolved in a timely manner. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis Direct Loan, 34 CFR section 685.309. Condition Through our testing of 100 enrollment reporting selections across 4 campuses, we noted the following at 2 campuses: ? For 3 of 25 selections at one campus, we noted that the effective date of the change per NSLDS did not agree to the effective date of the actual status change per the student file. In each of these instances, the student was changing from part-time to full-time . ? For 4 of 25 selections at a third campus, we noted that the students were reported as withdrawn when they should have been reported as graduated . Our understanding in each of the scenarios above, is that there would be no impact on repayment dates for students with loans, and thus these errors do not result in questioned costs or have an impact to the student or federal government. Cause ? The cause of the reporting finding at the first campus is that there was a system error that was backdating the campus-level enrollment effective date to the first date of the term when a student increased attendance, which is why the effective date per NSLDS did not agree to the effective date in the student file. ? Regarding the second campus, this finding relates to the sequence of reporting enrollment changes during the summer, and ultimately has a broader impact going back several years. During the summer, management noted they correctly reported graduated status more than once. However, in their final summer enrollment file, the status for these students was noted to be full-time status, which was true, but this full-time status overwrote their previously reported graduated status. Under standard practice, when these students did not appear in the fall enrollment file, the National Student Clearinghouse derived a withdrawn status, which was reported to NSLDS. There were also various error reports for which this campus was behind on fully resolving, resulting in this issue not being identified by management Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure COD error reports are resolved in a timely manner. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and Iraq and Afghanistan Service Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution on the advance method follows up with a disbursement record for that student no earlier than 7 calendar days prior to the disbursement date under the advance or heightened cash monitoring payment methods. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. The Compliance Supplement notes that the key items for an auditor to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when applicable), transaction number, cost of attendance, and academic calendar. Key items to test on disbursement records are disbursement date and amount. Condition Through our testing of 100 selections across 4 campuses, we noted at one campus that the date of disbursement per the COD did not match the date per the student account detail for 12 out of 25 selections. Additionally, 5 of the 25 selections were not reported to the COD within 15 calendar days of the disbursement to the student. On average, the 5 disbursements were reported 9 calendar days late. Lastly, for one selection, a student was reported into the COD 8 days before the disbursement, which is 1 day earlier than permitted by the regulation . Cause Through discussions with management, they noted that the errors and late/early reporting were due to staffing and training issues, as they continue to be challenged with staff retention and recruitment. Effect Inaccurate information within the COD system could lead to inaccurate information in reports utilized by the Department of Education. Questioned Costs None noted. Recommendation We recommend the campus provide additional training on COD reporting requirements, including on the disbursement dates that should be reported and the timeline for reporting and that additional reviews be considered to identify potential errors prior to submission into the COD. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-006 ? Quarterly Higher Education Emergency Relief Fund (HEERF) Reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion and COVID-19 HEERF Supplemental Assistance to Institutions of Higher Education (SAIHE) Program Award Numbers: P425F202269 and P425S210019 Assistance Listing Titles: COVID-19 HEERF Student Portion and COVID-19 HEERF SAIHE Program Assistance Listing Number: 84.425E and 84.425S Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The quarterly HEERF reporting format requires institutions to report the total amount of HEERF (a)(1) Student Aid disbursed directly to students as Emergency Financial Aid Grants along with other information. (a)(1) is equivalent to funds disbursed under Assistance Listing #84.425E. SAIHE funds are considered (a)(3) funds and are required to be reported in a separate section of the quarterly HEERF report. Reports are required to be posted to an institution's website 10 days after each calendar quarter end. Condition Through our testing of 14 quarterly student and institutional reports across 4 campuses, we noted the following at 1 campus : ? Through our testing, we reconciled the total cumulative student spending as reported on the June 30, 2022 quarterly report to the total cumulative spending of the student portion at this campus and noted that total student funds reported were $1,505,755 in excess of the cumulative awards actually spent. This variance represented 50% of this campus?s award under 84.425S, which was awarded to students, however, this should not have been included in the 84.425E totals. ? The June 30, 2022 quarterly report was also submitted 2 days late. Cause Management did not realize that 84.425S funds awarded to students should not be commingled in the quarterly reports with the 84.425E student portion spending. Additionally, the due date of the report was a Sunday and instead of recognizing the report should be submitted the next business day or prior, it was submitted 2 days late. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None noted. Recommendation We recommend management amend their June 30, 2022 report to include the correct amounts and assess whether any other quarters are impacted. Additionally, they should implement a control to review proper classification of funds in future quarterly reports and to ensure timely submission. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-005 ? HEERF Institutional portion unallowable costs Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) II and III Institutional Portions Award Numbers: P425F202269 and P425F201852 - 20A Assistance Listing Title: COVID-19 HEERF Institutional Portion Assistance Listing Number: 84.425F Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The Department of Education Certification and Agreement for both HEERF II and HEERF III notes that recipients may use these grant funds for Institutional costs to defray expenses associated with COVID-19 (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll), and make additional emergency financial grants to students, which may be used for any component of the student?s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care), or child care. Cost of attendance, as defined under section 472 of the Higher Education Act, includes food, housing, course materials, technology, health care, and child-care. Condition Through our testing of 75 institutional portion costs across 3 campuses, we noted the following at 2 campuses: ? 1 out of 25 selections tested at one campus related to $250 scholarships awarded to 19 students totaling $4,750 for summer 2021. These scholarships were awarded to students participating in an early start academy to help the student prepare for future academic success. Criteria to qualify for the scholarships included earning a 2.5 GPA or higher, passing HESA 001, completing/turning in an education plan and attending 4 academic support sessions at the Academic Resource Center. This scholarship program was not related to awarding funds to students for emergency costs arising due to COVID-19 or for elements of the cost of attendance, as defined in the criteria above. In total, $58,000 in awards were made to students under this scholarship program in fiscal year 2022, which were not allowable costs per HEERF guidelines . ? At a second campus, we performed testing over $21,803,672 claimed in lost revenue, which was supported in part by $6,103,672 of lost rental revenue. Through our testing of individual leases making up the lost rental revenue, we noted : o 1 lease arrangement totaling $1,345,330 was selected for testing and management noted that this lease should have been excluded from the analysis. It was included in an initial analysis as reflecting potential lost revenue, but lost revenue was not ultimately realized and this lease was not appropriately removed in the final lost revenue analysis. o 1 lease in which the supporting spreadsheet calculation of lost revenue was incorrect. This lease had different terms than others in the spreadsheet, but lost revenue was calculated as if the terms were consistent with the other leases, resulting in an overstatement of lost revenue of $39,000. ? Additionally, at the second campus, for each of our 7 fringe benefit selections, totaling $19,581 we were unable to obtain support for the 52% fringe benefits rate used to derive the amount charged to the award. We were able to see approved hours worked on the award and support for the employee pay rates, however, the 52% rate used to derive the fringe benefits charged could not be provided by management. Cause ? In the first instance, the use of these funds went through all appropriate approval levels, including the Provost and Chancellor, however, there was a lack of understanding that this scholarship program did not meet the HEERF III criteria noted above. ? In the second instance, the impacted campus has a significant amount of leases and the process for tracking the leases, lease amendments due to COVID-19 and the associated lost revenue analysis was manual. There also was no formal evidence of review of this analysis prior to it being provided to central campus finance management. ? In the third instance, management could not locate the support for the rate used due to not maintaining complete internal records. Effect Given the nature of the expenses above, they were not eligible for reimbursement under HEERF and resulted in questioned costs. Questioned Costs $1,461,911 Recommendation We recommend management at the first campus review any future scholarship programs being funded with HEERF institutional funds to ensure they meet the criteria laid out in the HEERF certification and agreement. We recommend that management at the second campus review their lease tracking and management process and formalize controls over the review of future lost revenue analyses. Additionally, they should ensure support for all costs charged to the HEERF award can be fully supported, including support for the fringe benefits rate being charged. Additionally, in both of these scenarios, management should reverse these transactions, update quarterly HEERF reports, as needed, and determine if the funds can be used for other allowable purposes and/or return the funds to the federal government. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings. ay rates, however, the 52% rate used to derive the fringe benefits charged could not be provided by management.
2022-007 ? HEERF Procurement, Suspension and Debarment Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: P425F202269 Assistance Listing Title: COVID-19 HEERF Institutional Portion Assistance Listing Number: 84.425F Award Year: 2020-2022 Pass-through entity: Not applicable Criteria A non-Federal entity must have and use documented procurement procedures and is 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 with an entity at a lower tier, 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Through our testing of 12 selections across 3 campuses (out of a population of 54 across all 3 campuses) for both procurement and suspension and debarment, we noted the following for 2 out of 3 transactions selected for testing at 1 campus : ? Missing original Source Selection & Price Reasonableness justification forms demonstrating appropriate procurement decisions and approval took place prior to the transactions, which are required at this campus for transactions greater than $10,000. ? Management could not provide evidence that suspension and debarment checks were performed prior to purchase. We received evidence of the checks after the purchase. Cause Management indicated that the Source Selection & Price Reasonableness justification forms and the suspension and debarment checks were performed, however, they misplaced the original documentation. Effect The University may not follow appropriate procurement policies and procedures and may inappropriately do business with a vendor that is suspended or debarred if timely checks are not performed. Questioned Costs None noted. Recommendation We recommend that management reassess their document retention protocols and ensure controls are in place to ensure complete and accurate files, inclusive of timely suspension and debarment checks. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-008 ? Completeness and accuracy of certain COVID-19 programs on the Prior Year Schedule of Expenditures of Federal Awards (SEFA) - (Significant Deficiency) Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services (HHS) - Health Resources and Services Administration (HRSA) and Department of Education Award Names: COVID-19 Provider Relief Fund (PRF) and COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: Not applicable and P425F202269 Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution and COVID-19 HEERF Institutional Portion Assistance Listing Number: 93.498 and 84.425F Award Year: 2020-2021 and 2020-2022 Pass-through entity: Not applicable Criteria 2 CFR 200.510 Financial statements requires auditees to prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records and other federal guidance. Condition The following errors were identified in the University?s 2021 SEFA: ? Management at the University Office of the President brought to our attention that in the prior year, the PRF Period 1 expenditures at 1 hospital that was part of a certain medical center with multiple portal submissions, was not included on the University?s SEFA. This error totaled $26,358,874 and represented 6% of total Period 1 PRF expenditures included on the SEFA and 0.4% of the University?s total SEFA. Exclusion of this amount did not impact the major program determination in 2021 or our scoping of the PRF major program across the University as a whole. Management has included this amount on the 2022 SEFA. ? Through our discussions with management at a second campus, we identified 2 additional PRF portal submissions were excluded from the 2021 SEFA, as follows: Period 1 $473,339 and Period 1 $11,962. These submissions have also been included in the 2022 SEFA. ? Through our current year testing at a third campus, we noted that the 2021 HEERF institutional funds expended per management?s analysis did not agree to the amount reported on the 2021 SEFA. The amount reported in the prior year was understated by $1,296,498. This amount was not material to HEERF or to the 2021 SEFA as a whole. This amount has also been included in the 2022 SEFA. Cause The COVID-19 pandemic resulted in the receipt and expenditure of federal funds across certain University medical centers where there has previously been limited to no federal funding and a different nature of funding at certain of the campuses. The preparation of the SEFA requires information from each campus be provided to the University Office of the President for compilation, and the aggregation of the COVID-19 PRF funding was manual. In addition, there was limited knowledge of the federal funding at the medical centers and thus a reliance on the part of management that each campus was reporting complete and accurate information. A final reconciliation of all portal submissions compared to the amounts on the SEFA also failed to detect the missing PRF expenditures at this one medical center. Additionally, regarding the HEERF missing amounts, the correct amount was communicated by the campus to the University Office of the President, however, this communication was overlooked by the preparer of the SEFA, since a manual adjustment was required. Effect A SEFA that is not complete and accurate could impact the scoping of an entity?s major programs and result in incomplete information being provided to the federal government. Questioned Costs None noted. Recommendation We recommend updates on atypical federal programs (e.g., HEERF and PRF) at each campus (including the medical centers) be periodically provided to the team at the University Office of the President that is responsible for the compilation of the SEFA. This will allow for a more comprehensive understanding of the campus grant activity for these programs and the ability to better review and assess the completeness and accuracy reported for these programs on the University?s year-end SEFA, inclusive of these programs. One means by which this might be accomplished is to develop a checklist of anticipated awards by campus in advance of the year and also complete an interim SEFA to identify inconsistencies earlier in the fiscal year. We recommend the campuses review the interim SEFA for completeness and accuracy and provide a formal sign-off/approval to the University Office of the President. We also recommend formal review of the final year-end SEFA be evidenced by the Systemwide Controller or other appropriate personnel. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-006 ? Quarterly Higher Education Emergency Relief Fund (HEERF) Reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Names: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion and COVID-19 HEERF Supplemental Assistance to Institutions of Higher Education (SAIHE) Program Award Numbers: P425F202269 and P425S210019 Assistance Listing Titles: COVID-19 HEERF Student Portion and COVID-19 HEERF SAIHE Program Assistance Listing Number: 84.425E and 84.425S Award Year: 2020-2022 Pass-through entity: Not applicable Criteria The quarterly HEERF reporting format requires institutions to report the total amount of HEERF (a)(1) Student Aid disbursed directly to students as Emergency Financial Aid Grants along with other information. (a)(1) is equivalent to funds disbursed under Assistance Listing #84.425E. SAIHE funds are considered (a)(3) funds and are required to be reported in a separate section of the quarterly HEERF report. Reports are required to be posted to an institution's website 10 days after each calendar quarter end. Condition Through our testing of 14 quarterly student and institutional reports across 4 campuses, we noted the following at 1 campus : ? Through our testing, we reconciled the total cumulative student spending as reported on the June 30, 2022 quarterly report to the total cumulative spending of the student portion at this campus and noted that total student funds reported were $1,505,755 in excess of the cumulative awards actually spent. This variance represented 50% of this campus?s award under 84.425S, which was awarded to students, however, this should not have been included in the 84.425E totals. ? The June 30, 2022 quarterly report was also submitted 2 days late. Cause Management did not realize that 84.425S funds awarded to students should not be commingled in the quarterly reports with the 84.425E student portion spending. Additionally, the due date of the report was a Sunday and instead of recognizing the report should be submitted the next business day or prior, it was submitted 2 days late. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None noted. Recommendation We recommend management amend their June 30, 2022 report to include the correct amounts and assess whether any other quarters are impacted. Additionally, they should implement a control to review proper classification of funds in future quarterly reports and to ensure timely submission. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-008 ? Completeness and accuracy of certain COVID-19 programs on the Prior Year Schedule of Expenditures of Federal Awards (SEFA) - (Significant Deficiency) Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services (HHS) - Health Resources and Services Administration (HRSA) and Department of Education Award Names: COVID-19 Provider Relief Fund (PRF) and COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Numbers: Not applicable and P425F202269 Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution and COVID-19 HEERF Institutional Portion Assistance Listing Number: 93.498 and 84.425F Award Year: 2020-2021 and 2020-2022 Pass-through entity: Not applicable Criteria 2 CFR 200.510 Financial statements requires auditees to prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records and other federal guidance. Condition The following errors were identified in the University?s 2021 SEFA: ? Management at the University Office of the President brought to our attention that in the prior year, the PRF Period 1 expenditures at 1 hospital that was part of a certain medical center with multiple portal submissions, was not included on the University?s SEFA. This error totaled $26,358,874 and represented 6% of total Period 1 PRF expenditures included on the SEFA and 0.4% of the University?s total SEFA. Exclusion of this amount did not impact the major program determination in 2021 or our scoping of the PRF major program across the University as a whole. Management has included this amount on the 2022 SEFA. ? Through our discussions with management at a second campus, we identified 2 additional PRF portal submissions were excluded from the 2021 SEFA, as follows: Period 1 $473,339 and Period 1 $11,962. These submissions have also been included in the 2022 SEFA. ? Through our current year testing at a third campus, we noted that the 2021 HEERF institutional funds expended per management?s analysis did not agree to the amount reported on the 2021 SEFA. The amount reported in the prior year was understated by $1,296,498. This amount was not material to HEERF or to the 2021 SEFA as a whole. This amount has also been included in the 2022 SEFA. Cause The COVID-19 pandemic resulted in the receipt and expenditure of federal funds across certain University medical centers where there has previously been limited to no federal funding and a different nature of funding at certain of the campuses. The preparation of the SEFA requires information from each campus be provided to the University Office of the President for compilation, and the aggregation of the COVID-19 PRF funding was manual. In addition, there was limited knowledge of the federal funding at the medical centers and thus a reliance on the part of management that each campus was reporting complete and accurate information. A final reconciliation of all portal submissions compared to the amounts on the SEFA also failed to detect the missing PRF expenditures at this one medical center. Additionally, regarding the HEERF missing amounts, the correct amount was communicated by the campus to the University Office of the President, however, this communication was overlooked by the preparer of the SEFA, since a manual adjustment was required. Effect A SEFA that is not complete and accurate could impact the scoping of an entity?s major programs and result in incomplete information being provided to the federal government. Questioned Costs None noted. Recommendation We recommend updates on atypical federal programs (e.g., HEERF and PRF) at each campus (including the medical centers) be periodically provided to the team at the University Office of the President that is responsible for the compilation of the SEFA. This will allow for a more comprehensive understanding of the campus grant activity for these programs and the ability to better review and assess the completeness and accuracy reported for these programs on the University?s year-end SEFA, inclusive of these programs. One means by which this might be accomplished is to develop a checklist of anticipated awards by campus in advance of the year and also complete an interim SEFA to identify inconsistencies earlier in the fiscal year. We recommend the campuses review the interim SEFA for completeness and accuracy and provide a formal sign-off/approval to the University Office of the President. We also recommend formal review of the final year-end SEFA be evidenced by the Systemwide Controller or other appropriate personnel. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and Iraq and Afghanistan Service Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution on the advance method follows up with a disbursement record for that student no earlier than 7 calendar days prior to the disbursement date under the advance or heightened cash monitoring payment methods. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. The Compliance Supplement notes that the key items for an auditor to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when applicable), transaction number, cost of attendance, and academic calendar. Key items to test on disbursement records are disbursement date and amount. Condition Through our testing of 100 selections across 4 campuses, we noted at one campus that the date of disbursement per the COD did not match the date per the student account detail for 12 out of 25 selections. Additionally, 5 of the 25 selections were not reported to the COD within 15 calendar days of the disbursement to the student. On average, the 5 disbursements were reported 9 calendar days late. Lastly, for one selection, a student was reported into the COD 8 days before the disbursement, which is 1 day earlier than permitted by the regulation . Cause Through discussions with management, they noted that the errors and late/early reporting were due to staffing and training issues, as they continue to be challenged with staff retention and recruitment. Effect Inaccurate information within the COD system could lead to inaccurate information in reports utilized by the Department of Education. Questioned Costs None noted. Recommendation We recommend the campus provide additional training on COD reporting requirements, including on the disbursement dates that should be reported and the timeline for reporting and that additional reviews be considered to identify potential errors prior to submission into the COD. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis Direct Loan, 34 CFR section 685.309. Condition Through our testing of 100 enrollment reporting selections across 4 campuses, we noted the following at 2 campuses: ? For 3 of 25 selections at one campus, we noted that the effective date of the change per NSLDS did not agree to the effective date of the actual status change per the student file. In each of these instances, the student was changing from part-time to full-time . ? For 4 of 25 selections at a third campus, we noted that the students were reported as withdrawn when they should have been reported as graduated . Our understanding in each of the scenarios above, is that there would be no impact on repayment dates for students with loans, and thus these errors do not result in questioned costs or have an impact to the student or federal government. Cause ? The cause of the reporting finding at the first campus is that there was a system error that was backdating the campus-level enrollment effective date to the first date of the term when a student increased attendance, which is why the effective date per NSLDS did not agree to the effective date in the student file. ? Regarding the second campus, this finding relates to the sequence of reporting enrollment changes during the summer, and ultimately has a broader impact going back several years. During the summer, management noted they correctly reported graduated status more than once. However, in their final summer enrollment file, the status for these students was noted to be full-time status, which was true, but this full-time status overwrote their previously reported graduated status. Under standard practice, when these students did not appear in the fall enrollment file, the National Student Clearinghouse derived a withdrawn status, which was reported to NSLDS. There were also various error reports for which this campus was behind on fully resolving, resulting in this issue not being identified by management Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure COD error reports are resolved in a timely manner. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis Direct Loan, 34 CFR section 685.309. Condition Through our testing of 100 enrollment reporting selections across 4 campuses, we noted the following at 2 campuses: ? For 3 of 25 selections at one campus, we noted that the effective date of the change per NSLDS did not agree to the effective date of the actual status change per the student file. In each of these instances, the student was changing from part-time to full-time . ? For 4 of 25 selections at a third campus, we noted that the students were reported as withdrawn when they should have been reported as graduated . Our understanding in each of the scenarios above, is that there would be no impact on repayment dates for students with loans, and thus these errors do not result in questioned costs or have an impact to the student or federal government. Cause ? The cause of the reporting finding at the first campus is that there was a system error that was backdating the campus-level enrollment effective date to the first date of the term when a student increased attendance, which is why the effective date per NSLDS did not agree to the effective date in the student file. ? Regarding the second campus, this finding relates to the sequence of reporting enrollment changes during the summer, and ultimately has a broader impact going back several years. During the summer, management noted they correctly reported graduated status more than once. However, in their final summer enrollment file, the status for these students was noted to be full-time status, which was true, but this full-time status overwrote their previously reported graduated status. Under standard practice, when these students did not appear in the fall enrollment file, the National Student Clearinghouse derived a withdrawn status, which was reported to NSLDS. There were also various error reports for which this campus was behind on fully resolving, resulting in this issue not being identified by management Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure COD error reports are resolved in a timely manner. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition Through our testing of 100 students with Title IV awards who withdrew or otherwise left the University across 4 campuses, we noted the following at 2 campuses: ? 25 students were selected for testing at 1 campus and 6 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 5 out of 6 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late . ? 25 students were selected for testing at 1 campus and 15 of those 25 selections required a Title IV refund be submitted to the Department of Education. In 2 out of 15 of these instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 17 days late . Cause ? Management at the first campus indicated there were staffing transitions in the unit responsible for the return of Title IV calculations, which resulted in processing delays. ? Management at the second campus, indicated that due to staffing changes and training, the October COD file was submitted outside of the expected timeframe, resulting in the late returns of Title IV funds. Effect The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back. Questioned Costs None noted. Recommendation We recommend both campuses review their staffing and training protocols to ensure in the event of turnover that there are no gaps in the management Title IV refund requirements. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and Iraq and Afghanistan Service Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution on the advance method follows up with a disbursement record for that student no earlier than 7 calendar days prior to the disbursement date under the advance or heightened cash monitoring payment methods. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. The Compliance Supplement notes that the key items for an auditor to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when applicable), transaction number, cost of attendance, and academic calendar. Key items to test on disbursement records are disbursement date and amount. Condition Through our testing of 100 selections across 4 campuses, we noted at one campus that the date of disbursement per the COD did not match the date per the student account detail for 12 out of 25 selections. Additionally, 5 of the 25 selections were not reported to the COD within 15 calendar days of the disbursement to the student. On average, the 5 disbursements were reported 9 calendar days late. Lastly, for one selection, a student was reported into the COD 8 days before the disbursement, which is 1 day earlier than permitted by the regulation . Cause Through discussions with management, they noted that the errors and late/early reporting were due to staffing and training issues, as they continue to be challenged with staff retention and recruitment. Effect Inaccurate information within the COD system could lead to inaccurate information in reports utilized by the Department of Education. Questioned Costs None noted. Recommendation We recommend the campus provide additional training on COD reporting requirements, including on the disbursement dates that should be reported and the timeline for reporting and that additional reviews be considered to identify potential errors prior to submission into the COD. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.