Finding 2023-001; Federal Agency: U.S Department of Education; Program Name: COVID-19: Higher Education Emergency Relief Fund; Assistance Listing Number: 84.425F; Federal Award Year: Funding periods between April 28, 2020 through June 30, 2023; Compliance Requirement: Reporting; Finding Type: Significant Deficiency; Criteria: On July 17, 2022, Department of Education (ED) announced an updated format for the HEERF Quarterly Reporting effective for Q2 2022, report to be posted July 10, 2022. The quarterly reporting requirements involved publicly posting completed forms conspicuously on the institution’s website. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30). Condition, including perspective: Our procedures discovered that reports filed by Lehigh during the current fiscal year were not filed using the updated format published by the Department of Education. The University submitted its quarterly reports timely, however the reports were using an outdated format that did not have the data elements required in the new reporting format. We compared the information reported by the University to the updated reporting format and noted that the reports filed by Lehigh did not contain the information required in the updated reporting format. Additionally, the information was presented on an aggregate spending basis as opposed to a per quarter spending basis. Therefore, the reports did not accurately present the information; however, the total expenditures agreed to the quarter expenditures and were supportable. Cause and Effect: University personnel responsible for HEERF reporting failed to review updated supplemental information and guidance published by the Department of Education to ensure that the University was reporting all of the required information by using the updated reporting template for all quarterly reports submitted. As a result, certain information was not reported to the Department of Education or included on the University’s website. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend that Lehigh University strengthen its process and controls to ensure that they review updates provided by the awarding agency in order to ensure that they comply with the supplemental requirements for each of its federal programs. Views of Responsible Officials: Lehigh University accepts this finding. The University will coordinate with HEERF regarding resubmission of the FY23 expense reports using the correct reporting template to accurately present all required information. Lehigh notes that this finding is the result of staff oversight. We are committed to strengthening our training and supervision of staff entrusted with compliance.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
2023-003; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 690.83, all schools receiving Pell grant must submit Pell payment data to the Department through the Common Origination and Disbursement (COD) System Origination. Records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition, including Perspective: For 29 of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of Pell disbursements to the COD, the student’s Pell disbursement was not reported within 15 calendar days of when the disbursement was made to the students. Cause and Effect: During the beginning of the fall semester, the University implemented various system patches that impacted the timely reporting of certain batched information containing student disbursement data to be submitted to COD. While the University did identify the issue timely due to the related system changes they were unable to submit student disbursement information to the COD within the required 15 days of disbursement. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhances its current policies and procedures to ensure the timely reporting of Pell disbursements to COD. Views of Responsible Officials: Lehigh University accepts this finding. We are aware of the 15 calendar day requirement and have always met the deadline. Failure to report Pell Grant disbursements within 15 days in August of 2022 was the result of a well documented Ellucian defect that denied Lehigh the ability to obtain the required data from our Banner system. By the time Lehigh received a patch from Ellucian, we had missed the 15 day window. Ellucian acknowledged the bug and Lehigh accepted that it was an anomaly.
Finding 2023-001; Federal Agency: U.S Department of Education; Program Name: COVID-19: Higher Education Emergency Relief Fund; Assistance Listing Number: 84.425F; Federal Award Year: Funding periods between April 28, 2020 through June 30, 2023; Compliance Requirement: Reporting; Finding Type: Significant Deficiency; Criteria: On July 17, 2022, Department of Education (ED) announced an updated format for the HEERF Quarterly Reporting effective for Q2 2022, report to be posted July 10, 2022. The quarterly reporting requirements involved publicly posting completed forms conspicuously on the institution’s website. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30). Condition, including perspective: Our procedures discovered that reports filed by Lehigh during the current fiscal year were not filed using the updated format published by the Department of Education. The University submitted its quarterly reports timely, however the reports were using an outdated format that did not have the data elements required in the new reporting format. We compared the information reported by the University to the updated reporting format and noted that the reports filed by Lehigh did not contain the information required in the updated reporting format. Additionally, the information was presented on an aggregate spending basis as opposed to a per quarter spending basis. Therefore, the reports did not accurately present the information; however, the total expenditures agreed to the quarter expenditures and were supportable. Cause and Effect: University personnel responsible for HEERF reporting failed to review updated supplemental information and guidance published by the Department of Education to ensure that the University was reporting all of the required information by using the updated reporting template for all quarterly reports submitted. As a result, certain information was not reported to the Department of Education or included on the University’s website. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend that Lehigh University strengthen its process and controls to ensure that they review updates provided by the awarding agency in order to ensure that they comply with the supplemental requirements for each of its federal programs. Views of Responsible Officials: Lehigh University accepts this finding. The University will coordinate with HEERF regarding resubmission of the FY23 expense reports using the correct reporting template to accurately present all required information. Lehigh notes that this finding is the result of staff oversight. We are committed to strengthening our training and supervision of staff entrusted with compliance.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
Finding 2023-002; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Enrollment Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 674.19 for Federal Perkins Loans, 34 CFR Section 690.83 (b)(2) for Pell, 34 CFR Section 685.309 for Direct Loans, a student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition including perspective: For three out of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of students enrollment status change to NSLDS, the students status change was not reported to the National Student Loan Data System (NSLDS) within 60 days after the University was made aware of the students status change effective date. Cause and Effect: The University did not have sufficient controls in place to ensure timely reporting to the National Student Clearing House (NSC). As a result of that the information would not be transmitted timely to the NSLDS which would impact information regarding the status of students with federal loans. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its current policies and procedures to reasonably ensure student status changes are reported within the appropriate time requirements. Views of Responsible Officials: Lehigh University accepts this finding. The training of new staff is always a priority, but this finding is the result of unusual turnover. Staff are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes.
2023-003; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 690.83, all schools receiving Pell grant must submit Pell payment data to the Department through the Common Origination and Disbursement (COD) System Origination. Records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition, including Perspective: For 29 of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of Pell disbursements to the COD, the student’s Pell disbursement was not reported within 15 calendar days of when the disbursement was made to the students. Cause and Effect: During the beginning of the fall semester, the University implemented various system patches that impacted the timely reporting of certain batched information containing student disbursement data to be submitted to COD. While the University did identify the issue timely due to the related system changes they were unable to submit student disbursement information to the COD within the required 15 days of disbursement. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhances its current policies and procedures to ensure the timely reporting of Pell disbursements to COD. Views of Responsible Officials: Lehigh University accepts this finding. We are aware of the 15 calendar day requirement and have always met the deadline. Failure to report Pell Grant disbursements within 15 days in August of 2022 was the result of a well documented Ellucian defect that denied Lehigh the ability to obtain the required data from our Banner system. By the time Lehigh received a patch from Ellucian, we had missed the 15 day window. Ellucian acknowledged the bug and Lehigh accepted that it was an anomaly.