FAC Explorer

Audit 299647

FY End
2023-06-30
Total Expended
$16.42M
Findings
2
Programs
12
Organization: Washington and Lee University (VA)
Year: 2023 Accepted: 2024-03-28
Auditor: Kpmg LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
387477 2023-001 Material Weakness - P
963919 2023-001 Material Weakness - P

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $13.96M Yes 1
84.063 Federal Pell Grant Program $1.08M Yes 0
84.038 Federal Perkins Loan Program $470,015 Yes 0
84.033 Federal Work-Study Program $300,000 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $292,816 Yes 0
21.008 Low Income Taxpayer Clinics $87,000 - 0
47.074 Biological Sciences $80,348 - 0
47.041 Engineering $33,930 - 0
47.050 Geosciences $23,513 - 0
47.076 Education and Human Resources $20,587 - 0
15.945 Cooperative Research and Training Programs Ð Resources of the National Park System $13,536 - 0
15.670 Adaptive Science $6,403 - 0

Contacts

Name Title Type
MSVHQKG44VN5 Irma Bailey Auditee
5404584831 Wendy Lewis Auditor
No contacts on file

Notes to SEFA

Title: Federal Direct Loan Program Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) has been prepared on the accrual basis of accounting. All federal awards received directly and indirectly from federal agencies are included in this Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the financial statements. The University has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University participates in the Federal Direct Loan Program (CFDA Number 84.268) (the Program), which includes the Federal Direct Subsidized Loan Program, the Federal Direct Unsubsidized Loan Program, and the Federal Direct PLUS Program. The Program requires the University to request cash from the U.S. Department of Education and disburse such funds. The amounts included in the Schedule represent cash received in fiscal 2023 from the U.S. Department of Education under the Program. The University is responsible only for the performance of certain administrative functions with respect to the Program, and accordingly, these loans are not included in the University’s financial statements. It is not practicable to determine the balance of loans outstanding to students and former students of the University under the Program at June 30, 2023.
Title: Federal Perkins Loan Program Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) has been prepared on the accrual basis of accounting. All federal awards received directly and indirectly from federal agencies are included in this Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the financial statements. The University has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Federal Perkins Loan program is administered directly by the University and balances and transactions relating to the program is included in notes receivable, net, in the University’s financial statements. The Federal Perkins program is no longer issuing new loans; thus, the current year loaned amount was zero. The amount of Federal Perkins loans on the Schedule includes the outstanding loan balance as of June 30, 2022, the 2023 fiscal year loaned amount and the administrative charges, if any. The balance of loans outstanding under the Federal Perkins program was $395,083, as of June 30, 2023. The University did not receive a federal capital contribution for the year ended June 30, 2023.
Title: Reconciliation of Schedule of Expenditures of Federal Awards to Statement of Activities Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) has been prepared on the accrual basis of accounting. All federal awards received directly and indirectly from federal agencies are included in this Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the financial statements. The University has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal expenditures per the Schedule $ 1,986,493; Less federal grants considered agency transactions (1,675,764); Add nonfederal grants and contracts 950,254; Governmental and other grants per the statement of activities $ 1,260,983

Finding Details

Finding 2023-001
Findings and Questioned Costs Relating to Federal Awards 2023-001: Enrollment Reporting Federal Program – Student Financial Assistance Cluster – Noncash assistance – Federal Direct Student Loans Program (Assistance Listing No. 84.268) Federal Agency – U.S. Department of Education Federal Award Year – July 1, 2022 to June 30, 2023 Criteria Requirement 34 CFR 685.309 states that the administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the National Student Loan Data System (NLSDS) Professional Access (NSLDSFAP) website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by U.S. Department of Education (ED) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.) When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Found For 21 out of 40 enrollment status changes sampled, comparison of the institution’s records to that of NSLDS evidenced that enrollment reporting for these students were not accurately reflected within the NSLDS website. Therefore, Washington and Lee University did not report the accurate enrollment status to the NSLDS. Possible Cause and Asserted Effect Management’s review over its enrollment reporting requirements for SFA was not operating as designed to ensure accurate reporting of status changes. The personnel responsible for identifying and resolving edit checks noted by the National Student Clearinghouse (NSC) did not perform this step of the control implemented by management, thus, did not accurately communicate the students’ status changes Management determined that the personnel assigned these responsibilities were not adequately trained to complete this step of the control. As such, certain status changes were not reported accurately to NSLDS. Questioned Costs The questioned costs associated with this finding are not determinable as the finding is not of monetary nature. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample.Identification of Repeat Finding This finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the Washington and Lee University reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent or detect and correct noncompliance on a timely basis. Specifically, emphasizing the processes and controls around ensuring edit checks identified by the NSC are reviewed and resolved on a timely basis. Views of Responsible Officials The Washington and Lee University agrees with the findings and the recommendation. W&L has developed controls around the timeliness and accuracy of enrollment reporting. The instances of noncompliance were due to reliance on the NSC to identify and communicate potential errors in the accuracy of the student information uploaded to the NSC system instead of independently verifying there were no edit checks identified by the NSC as outlined in the design of the current internal controls implemented by the entity. As such, management has committed to reinforce and train the individuals in the compliance control ownership role with respect to the proper execution of the internal controls within the enrollment reporting.
Finding 2023-001
Findings and Questioned Costs Relating to Federal Awards 2023-001: Enrollment Reporting Federal Program – Student Financial Assistance Cluster – Noncash assistance – Federal Direct Student Loans Program (Assistance Listing No. 84.268) Federal Agency – U.S. Department of Education Federal Award Year – July 1, 2022 to June 30, 2023 Criteria Requirement 34 CFR 685.309 states that the administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the National Student Loan Data System (NLSDS) Professional Access (NSLDSFAP) website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by U.S. Department of Education (ED) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.) When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Found For 21 out of 40 enrollment status changes sampled, comparison of the institution’s records to that of NSLDS evidenced that enrollment reporting for these students were not accurately reflected within the NSLDS website. Therefore, Washington and Lee University did not report the accurate enrollment status to the NSLDS. Possible Cause and Asserted Effect Management’s review over its enrollment reporting requirements for SFA was not operating as designed to ensure accurate reporting of status changes. The personnel responsible for identifying and resolving edit checks noted by the National Student Clearinghouse (NSC) did not perform this step of the control implemented by management, thus, did not accurately communicate the students’ status changes Management determined that the personnel assigned these responsibilities were not adequately trained to complete this step of the control. As such, certain status changes were not reported accurately to NSLDS. Questioned Costs The questioned costs associated with this finding are not determinable as the finding is not of monetary nature. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample.Identification of Repeat Finding This finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the Washington and Lee University reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent or detect and correct noncompliance on a timely basis. Specifically, emphasizing the processes and controls around ensuring edit checks identified by the NSC are reviewed and resolved on a timely basis. Views of Responsible Officials The Washington and Lee University agrees with the findings and the recommendation. W&L has developed controls around the timeliness and accuracy of enrollment reporting. The instances of noncompliance were due to reliance on the NSC to identify and communicate potential errors in the accuracy of the student information uploaded to the NSC system instead of independently verifying there were no edit checks identified by the NSC as outlined in the design of the current internal controls implemented by the entity. As such, management has committed to reinforce and train the individuals in the compliance control ownership role with respect to the proper execution of the internal controls within the enrollment reporting.