2022 ? 003 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Two exceptions were observed during return of Title IV fund (R2T4) testing for students who did not have documentation for their participation in online courses. One of these students had an incorrect last date of attendance as a result. Questioned costs: None Cause: Lack of formal review of last date of attendance for online students including Canvas activity logs. Effect: Incorrect last date of attendance used in Return of Title IV funds calculation which would result in incorrect refund amounts and incorrect withdrawal date reported to NSLDS. Repeat finding: No Recommendation: CLA recommends the institution review student activity logs in Canvas when determining an online student?s last date of attendance. View of responsible official: The University agrees with the finding.
2022 ? 004 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Twenty exceptions were observed during Enrollment Reporting testing. Among the twenty students, six students had the incorrect enrollment status reported to the NSLDS, two students did not have any records in NSLDS, eleven students? status enrollment changes were reported beyond the sixty-day allowable timeframe, and nine students has status dates that did not agree to the "Enrollment Effective Date" in NSLDS. Questioned costs: None Cause: At the campus, there is a process that is run by the registrar for unofficial withdrawals at the end of every semester that overrides the correct institutional last date of attendance with the last date of the semester. This incorrect date is then reported to the Clearinghouse and ultimately NSLDS. This also impacts transfer students who may have their enrollment status incorrectly reported by the automated process. Effect: NEO was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes, see 2021-001 for the prior year finding. Recommendation: We recommend that the SFA department work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance and enrollment status prior to being reported to the Clearinghouse. View of responsible official: The University agrees with the finding.
2022 ? 002 Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F ? HEERF Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition and context: During the testing of the Northeastern Oklahoma A&M annual HEERF report CLA observed there was no formal review process of quarterly or annual reports which resulted in the annual report Institutional Expenditures in sections 8a and 9b of the Annual report to be overstated by $2,017,325. Questioned costs: None Cause: Northeastern Oklahoma A&M did not have a formal review process in place to review the accuracy of HEERF reports for the year ended June 30, 2022. Effect: Overstatement of institutional expenditures in the Annual Report for the year ended June 30, 2022. Repeat finding: No Recommendation: We recommend the Northeastern Oklahoma A&M implement a formal review process over the HEERF reports. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Two exceptions were observed during return of Title IV fund (R2T4) testing for students who did not have documentation for their participation in online courses. One of these students had an incorrect last date of attendance as a result. Questioned costs: None Cause: Lack of formal review of last date of attendance for online students including Canvas activity logs. Effect: Incorrect last date of attendance used in Return of Title IV funds calculation which would result in incorrect refund amounts and incorrect withdrawal date reported to NSLDS. Repeat finding: No Recommendation: CLA recommends the institution review student activity logs in Canvas when determining an online student?s last date of attendance. View of responsible official: The University agrees with the finding.
2022 ? 004 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Twenty exceptions were observed during Enrollment Reporting testing. Among the twenty students, six students had the incorrect enrollment status reported to the NSLDS, two students did not have any records in NSLDS, eleven students? status enrollment changes were reported beyond the sixty-day allowable timeframe, and nine students has status dates that did not agree to the "Enrollment Effective Date" in NSLDS. Questioned costs: None Cause: At the campus, there is a process that is run by the registrar for unofficial withdrawals at the end of every semester that overrides the correct institutional last date of attendance with the last date of the semester. This incorrect date is then reported to the Clearinghouse and ultimately NSLDS. This also impacts transfer students who may have their enrollment status incorrectly reported by the automated process. Effect: NEO was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes, see 2021-001 for the prior year finding. Recommendation: We recommend that the SFA department work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance and enrollment status prior to being reported to the Clearinghouse. View of responsible official: The University agrees with the finding.
2022 ? 002 Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F ? HEERF Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition and context: During the testing of the Northeastern Oklahoma A&M annual HEERF report CLA observed there was no formal review process of quarterly or annual reports which resulted in the annual report Institutional Expenditures in sections 8a and 9b of the Annual report to be overstated by $2,017,325. Questioned costs: None Cause: Northeastern Oklahoma A&M did not have a formal review process in place to review the accuracy of HEERF reports for the year ended June 30, 2022. Effect: Overstatement of institutional expenditures in the Annual Report for the year ended June 30, 2022. Repeat finding: No Recommendation: We recommend the Northeastern Oklahoma A&M implement a formal review process over the HEERF reports. Views of responsible officials: There is no disagreement with the audit finding.