Audit 27226

FINDING 2022-003 ? Reporting ?Significant Deficiency in Internal Control over Compliance CFDA Number(s) Name of Federal Program or Cluster Federal Award Number Award Year Questioned Costs 84.425 E 84.425 F 84.425 L COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund N/A Year ended May 31, 2022 $0 Criteria ? 86 FR 26213 requires Education Stabilization Fund (?ESF?) recipients to post the Student Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Condition/Context ? Grant amounts and expenditures of student funds reported on the University?s website were not reported timely for the quarter ending December 31, 2021. Additionally, during our initial walkthrough of the control processes with University personnel, we were unable to identify a control related to the review and approval of the required quarterly reports. Questioned Costs ? No questioned costs were identified as part of this finding. Effect or Potential Effect ? The required quarterly student reporting posted to the University?s website was not reported timely as required by the conditions of the grant. Cause ? The exceptions occurred as a result of the lack of internal controls in place to effectively review and approve published data in accordance with underlying Federal regulations. Recommendation ? We recommend that the University implement a process by which reported ESF expenditures are compared against applicable grant award notifications to ensure complete and accurate information is contained in the required quarterly reporting posted to the University?s website. Views of Responsible Officials and Planned Corrective Actions ? As indicated, the University did not post the student required HEERF until January 19, 2022; 9 days after the deadline due to oversight. This was the final report. The Department has since consolidated the reporting for student and institutional HEERF reporting. The University controller is now responsible for all student and institutional reporting.

FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control over Compliance CFDA Number(s) Name of Federal Program or Cluster Federal Award Number Award Year Questioned Costs Various Student Financial Assistance Cluster N/A Year ended May 31, 2022 Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Criteria ? 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is? i. Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student?s withdrawal date, if this date occurs on or before? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or ii. 100 percent, if the student?s withdrawal date occurs after? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context ? A sample of 15 out of a population of approximately 72 federal aid recipient students whom withdrew, dropped out, or enrolled but never attended during the 2021-2022 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origin and Disbursement system. For 2 of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the students. Questioned Costs ? Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Effect ? When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause ? The University incorrectly based calculations on the default status of full-time rather than adjusting the calculation for part-time students. Recommendation ? We recommend the University implement a process to review student enrollment status to ensure funds returned to students appropriately reflect whether they have full-time or part-time status. Views of Responsible Officials and Planned Corrective Actions ? When performing Return of Title 4 (RT24) calculations for PGS students who withdrew early in the term and were receiving Federal Pell Grant, the University reduced the Pell grant to the new enrollment level, but did not code the Colleague system with the revised enrollment level. Also, the University did not update the enrollment level code to match only the number of courses that the student started. The University has corrected all the past R2T4 calculations that were done in error. The University has revised its procedures to prevent this error from reoccurring.

FINDING 2022-003 ? Reporting ?Significant Deficiency in Internal Control over Compliance CFDA Number(s) Name of Federal Program or Cluster Federal Award Number Award Year Questioned Costs 84.425 E 84.425 F 84.425 L COVID-19 ? Education Stabilization Fund ? Higher Education Emergency Relief Fund N/A Year ended May 31, 2022 $0 Criteria ? 86 FR 26213 requires Education Stabilization Fund (?ESF?) recipients to post the Student Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Condition/Context ? Grant amounts and expenditures of student funds reported on the University?s website were not reported timely for the quarter ending December 31, 2021. Additionally, during our initial walkthrough of the control processes with University personnel, we were unable to identify a control related to the review and approval of the required quarterly reports. Questioned Costs ? No questioned costs were identified as part of this finding. Effect or Potential Effect ? The required quarterly student reporting posted to the University?s website was not reported timely as required by the conditions of the grant. Cause ? The exceptions occurred as a result of the lack of internal controls in place to effectively review and approve published data in accordance with underlying Federal regulations. Recommendation ? We recommend that the University implement a process by which reported ESF expenditures are compared against applicable grant award notifications to ensure complete and accurate information is contained in the required quarterly reporting posted to the University?s website. Views of Responsible Officials and Planned Corrective Actions ? As indicated, the University did not post the student required HEERF until January 19, 2022; 9 days after the deadline due to oversight. This was the final report. The Department has since consolidated the reporting for student and institutional HEERF reporting. The University controller is now responsible for all student and institutional reporting.

FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control over Compliance CFDA Number(s) Name of Federal Program or Cluster Federal Award Number Award Year Questioned Costs Various Student Financial Assistance Cluster N/A Year ended May 31, 2022 Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Criteria ? 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is? i. Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student?s withdrawal date, if this date occurs on or before? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or ii. 100 percent, if the student?s withdrawal date occurs after? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context ? A sample of 15 out of a population of approximately 72 federal aid recipient students whom withdrew, dropped out, or enrolled but never attended during the 2021-2022 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origin and Disbursement system. For 2 of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the students. Questioned Costs ? Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Effect ? When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause ? The University incorrectly based calculations on the default status of full-time rather than adjusting the calculation for part-time students. Recommendation ? We recommend the University implement a process to review student enrollment status to ensure funds returned to students appropriately reflect whether they have full-time or part-time status. Views of Responsible Officials and Planned Corrective Actions ? When performing Return of Title 4 (RT24) calculations for PGS students who withdrew early in the term and were receiving Federal Pell Grant, the University reduced the Pell grant to the new enrollment level, but did not code the Colleague system with the revised enrollment level. Also, the University did not update the enrollment level code to match only the number of courses that the student started. The University has corrected all the past R2T4 calculations that were done in error. The University has revised its procedures to prevent this error from reoccurring.