Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-005: Perkins Loan Recordkeeping and Record Retention Program: Federal Perkins Loan Program CFDA Number: 84.038 Federal Agency: U.S. Department of Education Federal Award Identification Number: Not applicable Federal Award Year: June 30, 2022 Criteria: 34 CFR 674.19 requires that an institution retains disbursement, electronic authentication and signature records and repayment records, including cancellation and deferment requests for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: For 1 borrower selected for testing, the University was unable to locate the original signed MPN. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 1 of the 50 students who were tested. Included in the sample were 25 borrowers with open loans as of May 31, 2022 and 25 borrowers with loans retired or assigned loans within the previous three fiscal years and the current fiscal year. A total of 460 borrowers had outstanding Perkins loan balances as of May 31, 2022 and another 291 borrowers had loans that were retired or assigned within the three previous years and the current fiscal year. The sample was not considered statistically valid. Effect: The University may not have appropriate supporting documentation that the original Perkins loan obligation existed and may not have a legally enforceable claim to collect remaining payments due on the loan. Cause: The original signed MPN was inadvertently disposed of at some point in the past prior to maintaining the documentation for the required time period. Recommendation: We recommend that University review Perkins loan record keeping requirements and double check that all record retention periods have ended prior to disposing of any Perkins loan records. Management's Response: Briar Cliff University has maintained all records related to Perkins loan, even though these loans have been discontinued since September 2017. The University has no intentions to delete or remove any documents until the time is appropriate. The current staff unfortunately was not employed when these records were originally collected or reviewed.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-006: Material Weakness - Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221428 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-004 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 12 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 21 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 11 students tested, the change of enrollment status was not reported within the 60 day requirement. For 6 students tested, in the program-level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 9 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. For 1 student tested, in the program-level record, the program the student was enrolled in, and the related Classification of Instructional Programs (CIP) code, reported to NSLDS did not match the University's records. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 28 of the 40 students who were tested. 11 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 12 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 21 students did not match the University's records, the program begin date reported to NSLDS for 6 students did not match the University's records, the program length reported to NSLDS for 9 students did not match the University's records, and the program enrolled, and related CIP code reported to NSLDS for 1 student did not match the University's records. A total of 402 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2022. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management's Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar's Office currently follows and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar's Office has been trained and is in compliance.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-005: Perkins Loan Recordkeeping and Record Retention Program: Federal Perkins Loan Program CFDA Number: 84.038 Federal Agency: U.S. Department of Education Federal Award Identification Number: Not applicable Federal Award Year: June 30, 2022 Criteria: 34 CFR 674.19 requires that an institution retains disbursement, electronic authentication and signature records and repayment records, including cancellation and deferment requests for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: For 1 borrower selected for testing, the University was unable to locate the original signed MPN. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 1 of the 50 students who were tested. Included in the sample were 25 borrowers with open loans as of May 31, 2022 and 25 borrowers with loans retired or assigned loans within the previous three fiscal years and the current fiscal year. A total of 460 borrowers had outstanding Perkins loan balances as of May 31, 2022 and another 291 borrowers had loans that were retired or assigned within the three previous years and the current fiscal year. The sample was not considered statistically valid. Effect: The University may not have appropriate supporting documentation that the original Perkins loan obligation existed and may not have a legally enforceable claim to collect remaining payments due on the loan. Cause: The original signed MPN was inadvertently disposed of at some point in the past prior to maintaining the documentation for the required time period. Recommendation: We recommend that University review Perkins loan record keeping requirements and double check that all record retention periods have ended prior to disposing of any Perkins loan records. Management's Response: Briar Cliff University has maintained all records related to Perkins loan, even though these loans have been discontinued since September 2017. The University has no intentions to delete or remove any documents until the time is appropriate. The current staff unfortunately was not employed when these records were originally collected or reviewed.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-006: Material Weakness - Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221428 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-004 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 12 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 21 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 11 students tested, the change of enrollment status was not reported within the 60 day requirement. For 6 students tested, in the program-level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 9 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. For 1 student tested, in the program-level record, the program the student was enrolled in, and the related Classification of Instructional Programs (CIP) code, reported to NSLDS did not match the University's records. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 28 of the 40 students who were tested. 11 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 12 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 21 students did not match the University's records, the program begin date reported to NSLDS for 6 students did not match the University's records, the program length reported to NSLDS for 9 students did not match the University's records, and the program enrolled, and related CIP code reported to NSLDS for 1 student did not match the University's records. A total of 402 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2022. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management's Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar's Office currently follows and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar's Office has been trained and is in compliance.
Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient begins attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.