Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (“HEERF”) Historically Black Colleges and Universities (“HBCUs”) (Assistance Listing #84.425J) and HEERF Supplemental Support under the American Rescue Plan (Assistance Listing #84.425T)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – There are three components to reporting for the Higher Education Emergency Relief Fund (“HEERF”): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report.
Condition: The University did not post 2 quarterly reports selected for testing for the year ended June 30, 2023.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirement of the HEERF program.
Questioned Costs: None.
Context: For 2 of 3 quarterly reports selected for testing the University did not publicly post the reports to the University’s website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-005.
Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that the quarterly reports are prepared and posted within the required time frames.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (“HEERF”) Historically Black Colleges and Universities (“HBCUs”) (Assistance Listing #84.425J) and HEERF Supplemental Support under the American Rescue Plan (Assistance Listing #84.425T)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – There are three components to reporting for the Higher Education Emergency Relief Fund (“HEERF”): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report.
Condition: The University did not post 2 quarterly reports selected for testing for the year ended June 30, 2023.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirement of the HEERF program.
Questioned Costs: None.
Context: For 2 of 3 quarterly reports selected for testing the University did not publicly post the reports to the University’s website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-005.
Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that the quarterly reports are prepared and posted within the required time frames.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period.
When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school.
Condition: For 2 students selected for testing, the University was unable to provide evidence that the student’s Perkins Loan repayment schedule was retained as required.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements.
Questioned Costs: None.
Context: For 2 of 40 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted.
Identification as a Repeat Finding: This is a repeat or prior year finding 2022-008.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website.
Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students.
Questioned Costs: None.
Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003.
Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis.
In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately.
As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007.
Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team.
As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (“HEERF”) Historically Black Colleges and Universities (“HBCUs”) (Assistance Listing #84.425J) and HEERF Supplemental Support under the American Rescue Plan (Assistance Listing #84.425T)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – There are three components to reporting for the Higher Education Emergency Relief Fund (“HEERF”): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report.
Condition: The University did not post 2 quarterly reports selected for testing for the year ended June 30, 2023.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirement of the HEERF program.
Questioned Costs: None.
Context: For 2 of 3 quarterly reports selected for testing the University did not publicly post the reports to the University’s website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-005.
Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that the quarterly reports are prepared and posted within the required time frames.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (“HEERF”) Historically Black Colleges and Universities (“HBCUs”) (Assistance Listing #84.425J) and HEERF Supplemental Support under the American Rescue Plan (Assistance Listing #84.425T)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – There are three components to reporting for the Higher Education Emergency Relief Fund (“HEERF”): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report.
Condition: The University did not post 2 quarterly reports selected for testing for the year ended June 30, 2023.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirement of the HEERF program.
Questioned Costs: None.
Context: For 2 of 3 quarterly reports selected for testing the University did not publicly post the reports to the University’s website.
Identification as a Repeat Finding: This is a repeat of prior year finding 2022-005.
Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that the quarterly reports are prepared and posted within the required time frames.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies.
Management and implementation of current corrective plans are critical to the compliance efforts of the University:
To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement.
Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students.
Questioned Costs: None.
Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements.
The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.
Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period.
When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school.
Condition: For 2 students selected for testing, the University was unable to provide evidence that the student’s Perkins Loan repayment schedule was retained as required.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements.
Questioned Costs: None.
Context: For 2 of 40 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted.
Identification as a Repeat Finding: This is a repeat or prior year finding 2022-008.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards.
Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation.
Cause: Administrative and internal control oversight.
Effect or Potential Effect: The University was not in compliance with the special reporting requirements.
Questioned Costs: None.
Context: For 1 of 1 report selected for Special Reporting testing.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements.
Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations.
In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department.
The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary.
In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.