2023-001 Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Numbers: 84.063; 84.268
Federal Award Identification Number and Year: Federal Pell Grant Program 2023 – P063P232128, P063P222128, P063Q222128; Federal Direct Student Loans 2023 – P268K247031, P268K247015, P268K242128, P268K237031, P268K237015, P268K232128, P268K227031, P268K227015, P268K222128.
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs: None.
Context: During our testing, we noted the following:
• In our sample of 40 students tested, 14 students were reported with the incorrect published program length per program-level NSLDS.
• In our sample of 40 students tested, 1 student were not reported to the campus-level record in the NSLDS in a timely manner.
Cause: Published program length set by the University is based on the 45-week academic year in place for graduate programs. However, when this information is reported to NSLDS, NSLDS bases this calculation on the typically 30-week academic year, causing the incorrect program length to be reflected in NSLDS.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: No.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-001 Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Numbers: 84.063; 84.268
Federal Award Identification Number and Year: Federal Pell Grant Program 2023 – P063P232128, P063P222128, P063Q222128; Federal Direct Student Loans 2023 – P268K247031, P268K247015, P268K242128, P268K237031, P268K237015, P268K232128, P268K227031, P268K227015, P268K222128.
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs: None.
Context: During our testing, we noted the following:
• In our sample of 40 students tested, 14 students were reported with the incorrect published program length per program-level NSLDS.
• In our sample of 40 students tested, 1 student were not reported to the campus-level record in the NSLDS in a timely manner.
Cause: Published program length set by the University is based on the 45-week academic year in place for graduate programs. However, when this information is reported to NSLDS, NSLDS bases this calculation on the typically 30-week academic year, causing the incorrect program length to be reflected in NSLDS.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: No.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-002 Reporting
Federal Agency: Federal Emergency Management Agency
Federal Program Names: COVID-19, Disaster Grants – Public Assistance
Assistance Listing Number: 97.036
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Uniform guidance requires the auditee to prepare a schedule of expenditures of federal awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510.
Condition: It was identified that there were expenditures included on SEFA for the year ended June 30, 2023 that were for awards obligated in the prior fiscal year.
Questioned Costs: None.
Context: There are $78,859 reported on the current year SEFA that should have been reported on the SEFA for the period ended June 30, 2022.
Cause: The University’s policies and procedures did not ensure that funds obligated in the prior fiscal year were appropriately included on the SEFA.
Effect: Amounts reported on the current year SEFA should have been reported on the prior year SEFA.
Repeat Finding: No.
Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate.
Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Perkins Compliance Report
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Perkins Loan Program
Assistance Listing Number: 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. 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 service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit.
Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements.
Questioned Costs: None.
Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report.
Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer
Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution.
Repeat Finding: No.
Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform.
Views of responsible officials: There is no disagreement with the audit finding.
2023-001 Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Numbers: 84.063; 84.268
Federal Award Identification Number and Year: Federal Pell Grant Program 2023 – P063P232128, P063P222128, P063Q222128; Federal Direct Student Loans 2023 – P268K247031, P268K247015, P268K242128, P268K237031, P268K237015, P268K232128, P268K227031, P268K227015, P268K222128.
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs: None.
Context: During our testing, we noted the following:
• In our sample of 40 students tested, 14 students were reported with the incorrect published program length per program-level NSLDS.
• In our sample of 40 students tested, 1 student were not reported to the campus-level record in the NSLDS in a timely manner.
Cause: Published program length set by the University is based on the 45-week academic year in place for graduate programs. However, when this information is reported to NSLDS, NSLDS bases this calculation on the typically 30-week academic year, causing the incorrect program length to be reflected in NSLDS.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: No.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-001 Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Numbers: 84.063; 84.268
Federal Award Identification Number and Year: Federal Pell Grant Program 2023 – P063P232128, P063P222128, P063Q222128; Federal Direct Student Loans 2023 – P268K247031, P268K247015, P268K242128, P268K237031, P268K237015, P268K232128, P268K227031, P268K227015, P268K222128.
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs: None.
Context: During our testing, we noted the following:
• In our sample of 40 students tested, 14 students were reported with the incorrect published program length per program-level NSLDS.
• In our sample of 40 students tested, 1 student were not reported to the campus-level record in the NSLDS in a timely manner.
Cause: Published program length set by the University is based on the 45-week academic year in place for graduate programs. However, when this information is reported to NSLDS, NSLDS bases this calculation on the typically 30-week academic year, causing the incorrect program length to be reflected in NSLDS.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: No.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-002 Reporting
Federal Agency: Federal Emergency Management Agency
Federal Program Names: COVID-19, Disaster Grants – Public Assistance
Assistance Listing Number: 97.036
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Uniform guidance requires the auditee to prepare a schedule of expenditures of federal awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510.
Condition: It was identified that there were expenditures included on SEFA for the year ended June 30, 2023 that were for awards obligated in the prior fiscal year.
Questioned Costs: None.
Context: There are $78,859 reported on the current year SEFA that should have been reported on the SEFA for the period ended June 30, 2022.
Cause: The University’s policies and procedures did not ensure that funds obligated in the prior fiscal year were appropriately included on the SEFA.
Effect: Amounts reported on the current year SEFA should have been reported on the prior year SEFA.
Repeat Finding: No.
Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate.
Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Perkins Compliance Report
Federal Agency: U.S. Department of Education
Federal Program Names: Federal Perkins Loan Program
Assistance Listing Number: 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. 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 service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit.
Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements.
Questioned Costs: None.
Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report.
Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer
Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution.
Repeat Finding: No.
Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform.
Views of responsible officials: There is no disagreement with the audit finding.