Finding 2022-005 - Material Weakness - Enrollment Reporting
Repeat of Prior Year Finding 2021-003
Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans
Federal Agency: Department of Education
Assistance Listing Number: 84.063, 84.268
Federal Award Year: June 30, 2022
Criteria: An institution is required to update students' changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309).
Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as 'withdrawn' from the University.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not properly reporting status changes to NSLDS.
Effect: The University was not in compliance with the required reporting requirements of student status changes.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For 25 of the 25 students selected for testing, the University did not submit status change notifications within the required time frames. The sample was not a statistically valid sample.
For 3 of the 25 students selected for testing, the University did not submit a campus level status change notification. The sample was not a statistically valid sample.
For 185 graduates, the University did not report the proper status change to NSLDS.
Recommendation: The University should revise its procedures for reporting student status changes to ensure that status changes are reported timely and accurately to NSLDS.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-005 - Material Weakness - Enrollment Reporting
Repeat of Prior Year Finding 2021-003
Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans
Federal Agency: Department of Education
Assistance Listing Number: 84.063, 84.268
Federal Award Year: June 30, 2022
Criteria: An institution is required to update students' changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309).
Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as 'withdrawn' from the University.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not properly reporting status changes to NSLDS.
Effect: The University was not in compliance with the required reporting requirements of student status changes.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For 25 of the 25 students selected for testing, the University did not submit status change notifications within the required time frames. The sample was not a statistically valid sample.
For 3 of the 25 students selected for testing, the University did not submit a campus level status change notification. The sample was not a statistically valid sample.
For 185 graduates, the University did not report the proper status change to NSLDS.
Recommendation: The University should revise its procedures for reporting student status changes to ensure that status changes are reported timely and accurately to NSLDS.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-006 - Significant Deficiency - Return of Title IV Funds
Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.268, 84.063
Federal Award Year: June 30, 2022
Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not completing the required return calculations.
Effect: Students did not receive proper refunds and the University was not in compliance with federal requirements.
Questioned Costs: The total amount that was under-refunded to students was $5,055.
Context: Calculations for 4 out of 5 students selected for testing were not completed. The sample was not a statistically valid sample.
Recommendation: The University should modify its procedures for refunding awards to ensure the proper refund is calculated correctly, as well as disbursing refunds in a timely manner.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-002 - Significant Deficiency - Review of School Account Statement (SAS) Reconciliations
Repeat of Prior Year Finding 2021-004
Program: Federal Direct Student Loans
Assistance Listing Number: 84.268
Federal Agency: U.S. Department of Education
Federal Award Year: June 30, 2022
Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements.
Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not being able to perform the reconciliations in the required timeframe.
Effect: The potential exists that an error could occur in the financial records and not be detected and corrected within a timely manner by employees in the normal course of performing their assigned functions.
Questioned Costs: Not applicable.
Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting.
Recommendation: The University should implement policies and procedures to ensure that the monthly SAS reconciliations are performed on a timely basis and correct all errors to adhere to federal regulations.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-003 - Overaward of Title IV Funds
Repeat of Prior Year Finding 2021-008
Federal Program - Federal Direct Loan Program
Federal Agency - U.S. Department of Education
Assistance Listing Number - 84.268
Federal Award Year - June 30, 2022
Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student's estimated financial assistance for that period and (2) the borrower's expected family contribution for that period.
Condition: During testing we noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student's financial assistance received to be greater than the student's cost of attendance.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not being able to correctly calculate the cost of attendance for one student, and erroneously awarding aid to a student who should not have received any aid.
Effect: The students received Title IV awards in excess of amounts they were eligible to receive.
Questioned Costs: One student was awarded $7,998 in excess of eligible Title IV funds.
Context: For 1 of 40 students, the University did not correctly calculate the cost of attendance. For 1 of 40 students the University awarded funds to an ineligible student. The sample was not a statistically valid sample.
Recommendation: The University should revise its procedures for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and that controls are in place to prevent overawards of Title IV funds.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-004 - Authorization for Retaining Credit Balance
Federal Program - Federal Direct Loan Program
Federal Agency - U.S. Department of Education
Assistance Listing Number - 84.268
Federal Award Year - June 30, 2022
Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold any Title IV program funds that would otherwise be paid directly to the student or parent as a credit balance.
Condition: During testing we noted one student had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not obtaining proper authorization or refunding the student's credit balance within the required time period.
Effect: The University did not properly refund the student's credit balance during the loan period.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For one of 40 students, the University did not have authorization to hold a credit balance past the loan period. The sample was not a statistically valid sample.
Recommendation: The University should revise its procedures for awarding Title IV aid, to ensure that aid is awarded correctly and that controls are in place to refund credit balances within the required time period.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-006 - Significant Deficiency - Return of Title IV Funds
Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.268, 84.063
Federal Award Year: June 30, 2022
Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not completing the required return calculations.
Effect: Students did not receive proper refunds and the University was not in compliance with federal requirements.
Questioned Costs: The total amount that was under-refunded to students was $5,055.
Context: Calculations for 4 out of 5 students selected for testing were not completed. The sample was not a statistically valid sample.
Recommendation: The University should modify its procedures for refunding awards to ensure the proper refund is calculated correctly, as well as disbursing refunds in a timely manner.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-007 - Significant Deficiency - Reporting
Repeat of Prior Year Finding 2021-011
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the University is required to post accurate and completed quarterly HEERF information to its primary website.
Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation.
Cause: Lack of competency and turnover in the business office contributed to the inadequate reporting.
Effect: The University was not in compliance with HEERF reporting requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: The University did not submit its annual report and certain quarterly reports submitted did not agree to underlying documentation. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with reporting requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-007 - Significant Deficiency - Reporting
Repeat of Prior Year Finding 2021-011
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the University is required to post accurate and completed quarterly HEERF information to its primary website.
Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation.
Cause: Lack of competency and turnover in the business office contributed to the inadequate reporting.
Effect: The University was not in compliance with HEERF reporting requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: The University did not submit its annual report and certain quarterly reports submitted did not agree to underlying documentation. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with reporting requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-008 - Cash Management
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University is required to disburse student aid payments within 15-calendar days after the draw down of the fund.
Condition: For 1 out of 35 students selected for testing the funds were disbursed to the students more than 15 days after funds were drawn down.
Cause: Lack of competency and turnover in the business office contributed to the delay in student disbursements.
Effect: The University was not in compliance with HEERF cash management requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: Student awards were disbursed to students more than 15 days after the drawdown of the funds for 1 out of 35 students tested. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with cash management requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-008 - Cash Management
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University is required to disburse student aid payments within 15-calendar days after the draw down of the fund.
Condition: For 1 out of 35 students selected for testing the funds were disbursed to the students more than 15 days after funds were drawn down.
Cause: Lack of competency and turnover in the business office contributed to the delay in student disbursements.
Effect: The University was not in compliance with HEERF cash management requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: Student awards were disbursed to students more than 15 days after the drawdown of the funds for 1 out of 35 students tested. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with cash management requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-009 - Allowable Costs and Activities
Repeat of Prior Year Finding 2021-012
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause: Lack of competency and turnover in the business office contributed to oversight in spending requirements of HEERF.
Effect: The University was not in compliance with ARP requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: No institutional awards were used in line with the ARP requirements.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with all applicable requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-009 - Allowable Costs and Activities
Repeat of Prior Year Finding 2021-012
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause: Lack of competency and turnover in the business office contributed to oversight in spending requirements of HEERF.
Effect: The University was not in compliance with ARP requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: No institutional awards were used in line with the ARP requirements.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with all applicable requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-005 - Material Weakness - Enrollment Reporting
Repeat of Prior Year Finding 2021-003
Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans
Federal Agency: Department of Education
Assistance Listing Number: 84.063, 84.268
Federal Award Year: June 30, 2022
Criteria: An institution is required to update students' changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309).
Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as 'withdrawn' from the University.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not properly reporting status changes to NSLDS.
Effect: The University was not in compliance with the required reporting requirements of student status changes.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For 25 of the 25 students selected for testing, the University did not submit status change notifications within the required time frames. The sample was not a statistically valid sample.
For 3 of the 25 students selected for testing, the University did not submit a campus level status change notification. The sample was not a statistically valid sample.
For 185 graduates, the University did not report the proper status change to NSLDS.
Recommendation: The University should revise its procedures for reporting student status changes to ensure that status changes are reported timely and accurately to NSLDS.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-005 - Material Weakness - Enrollment Reporting
Repeat of Prior Year Finding 2021-003
Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans
Federal Agency: Department of Education
Assistance Listing Number: 84.063, 84.268
Federal Award Year: June 30, 2022
Criteria: An institution is required to update students' changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309).
Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as 'withdrawn' from the University.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not properly reporting status changes to NSLDS.
Effect: The University was not in compliance with the required reporting requirements of student status changes.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For 25 of the 25 students selected for testing, the University did not submit status change notifications within the required time frames. The sample was not a statistically valid sample.
For 3 of the 25 students selected for testing, the University did not submit a campus level status change notification. The sample was not a statistically valid sample.
For 185 graduates, the University did not report the proper status change to NSLDS.
Recommendation: The University should revise its procedures for reporting student status changes to ensure that status changes are reported timely and accurately to NSLDS.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-006 - Significant Deficiency - Return of Title IV Funds
Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.268, 84.063
Federal Award Year: June 30, 2022
Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not completing the required return calculations.
Effect: Students did not receive proper refunds and the University was not in compliance with federal requirements.
Questioned Costs: The total amount that was under-refunded to students was $5,055.
Context: Calculations for 4 out of 5 students selected for testing were not completed. The sample was not a statistically valid sample.
Recommendation: The University should modify its procedures for refunding awards to ensure the proper refund is calculated correctly, as well as disbursing refunds in a timely manner.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-002 - Significant Deficiency - Review of School Account Statement (SAS) Reconciliations
Repeat of Prior Year Finding 2021-004
Program: Federal Direct Student Loans
Assistance Listing Number: 84.268
Federal Agency: U.S. Department of Education
Federal Award Year: June 30, 2022
Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements.
Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not being able to perform the reconciliations in the required timeframe.
Effect: The potential exists that an error could occur in the financial records and not be detected and corrected within a timely manner by employees in the normal course of performing their assigned functions.
Questioned Costs: Not applicable.
Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting.
Recommendation: The University should implement policies and procedures to ensure that the monthly SAS reconciliations are performed on a timely basis and correct all errors to adhere to federal regulations.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-003 - Overaward of Title IV Funds
Repeat of Prior Year Finding 2021-008
Federal Program - Federal Direct Loan Program
Federal Agency - U.S. Department of Education
Assistance Listing Number - 84.268
Federal Award Year - June 30, 2022
Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student's estimated financial assistance for that period and (2) the borrower's expected family contribution for that period.
Condition: During testing we noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student's financial assistance received to be greater than the student's cost of attendance.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not being able to correctly calculate the cost of attendance for one student, and erroneously awarding aid to a student who should not have received any aid.
Effect: The students received Title IV awards in excess of amounts they were eligible to receive.
Questioned Costs: One student was awarded $7,998 in excess of eligible Title IV funds.
Context: For 1 of 40 students, the University did not correctly calculate the cost of attendance. For 1 of 40 students the University awarded funds to an ineligible student. The sample was not a statistically valid sample.
Recommendation: The University should revise its procedures for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and that controls are in place to prevent overawards of Title IV funds.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-004 - Authorization for Retaining Credit Balance
Federal Program - Federal Direct Loan Program
Federal Agency - U.S. Department of Education
Assistance Listing Number - 84.268
Federal Award Year - June 30, 2022
Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold any Title IV program funds that would otherwise be paid directly to the student or parent as a credit balance.
Condition: During testing we noted one student had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not obtaining proper authorization or refunding the student's credit balance within the required time period.
Effect: The University did not properly refund the student's credit balance during the loan period.
Questioned Costs: There are no questioned costs associated with this finding.
Context: For one of 40 students, the University did not have authorization to hold a credit balance past the loan period. The sample was not a statistically valid sample.
Recommendation: The University should revise its procedures for awarding Title IV aid, to ensure that aid is awarded correctly and that controls are in place to refund credit balances within the required time period.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-006 - Significant Deficiency - Return of Title IV Funds
Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.268, 84.063
Federal Award Year: June 30, 2022
Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made.
Cause: Lack of competency and turnover in the financial aid office contributed to the University not completing the required return calculations.
Effect: Students did not receive proper refunds and the University was not in compliance with federal requirements.
Questioned Costs: The total amount that was under-refunded to students was $5,055.
Context: Calculations for 4 out of 5 students selected for testing were not completed. The sample was not a statistically valid sample.
Recommendation: The University should modify its procedures for refunding awards to ensure the proper refund is calculated correctly, as well as disbursing refunds in a timely manner.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements.
Finding 2022-007 - Significant Deficiency - Reporting
Repeat of Prior Year Finding 2021-011
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the University is required to post accurate and completed quarterly HEERF information to its primary website.
Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation.
Cause: Lack of competency and turnover in the business office contributed to the inadequate reporting.
Effect: The University was not in compliance with HEERF reporting requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: The University did not submit its annual report and certain quarterly reports submitted did not agree to underlying documentation. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with reporting requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-007 - Significant Deficiency - Reporting
Repeat of Prior Year Finding 2021-011
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the University is required to post accurate and completed quarterly HEERF information to its primary website.
Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation.
Cause: Lack of competency and turnover in the business office contributed to the inadequate reporting.
Effect: The University was not in compliance with HEERF reporting requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: The University did not submit its annual report and certain quarterly reports submitted did not agree to underlying documentation. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with reporting requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-008 - Cash Management
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University is required to disburse student aid payments within 15-calendar days after the draw down of the fund.
Condition: For 1 out of 35 students selected for testing the funds were disbursed to the students more than 15 days after funds were drawn down.
Cause: Lack of competency and turnover in the business office contributed to the delay in student disbursements.
Effect: The University was not in compliance with HEERF cash management requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: Student awards were disbursed to students more than 15 days after the drawdown of the funds for 1 out of 35 students tested. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with cash management requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-008 - Cash Management
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The University is required to disburse student aid payments within 15-calendar days after the draw down of the fund.
Condition: For 1 out of 35 students selected for testing the funds were disbursed to the students more than 15 days after funds were drawn down.
Cause: Lack of competency and turnover in the business office contributed to the delay in student disbursements.
Effect: The University was not in compliance with HEERF cash management requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: Student awards were disbursed to students more than 15 days after the drawdown of the funds for 1 out of 35 students tested. The sample was not a statistically valid sample.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with cash management requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-009 - Allowable Costs and Activities
Repeat of Prior Year Finding 2021-012
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause: Lack of competency and turnover in the business office contributed to oversight in spending requirements of HEERF.
Effect: The University was not in compliance with ARP requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: No institutional awards were used in line with the ARP requirements.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with all applicable requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.
Finding 2022-009 - Allowable Costs and Activities
Repeat of Prior Year Finding 2021-012
Federal Program: COVID-19 - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID-19 - HEERF Institutional Portion
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.425E, 84.425F
Federal Award Year: June 30, 2022
Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause: Lack of competency and turnover in the business office contributed to oversight in spending requirements of HEERF.
Effect: The University was not in compliance with ARP requirements.
Questioned Costs: There are no questioned costs associated with this finding.
Context: No institutional awards were used in line with the ARP requirements.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that it's in compliance with all applicable requirements.
Management's Response: Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about HEERF compliance requirements.