Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.425L, 84.031C
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2022-003 for 84.425L only.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.425L, 84.031C
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2022-003 for 84.425L only.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Questioned costs: None.
Context: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Cause: The University does not have formal procedures in place for reviewing calculations for funds to be drawn and reports prior to submission.
Effect: When separation of duties is inadequate, there is an increased risk that errors can occur and not be detected.
Repeat finding: Yes, 2022-004.
Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Questioned costs: None.
Context: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Cause: The University does not have formal procedures in place for reviewing calculations for funds to be drawn and reports prior to submission.
Effect: When separation of duties is inadequate, there is an increased risk that errors can occur and not be detected.
Repeat finding: Yes, 2022-004.
Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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 of enrollment information at both the program and campus-level detail, we noted the following:
15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status
17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records
25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner
1 out of 40 students’ published program lengths reported to the NSLDS was not correct
6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.
21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-005.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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 of enrollment information at both the program and campus-level detail, we noted the following:
15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status
17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records
25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner
1 out of 40 students’ published program lengths reported to the NSLDS was not correct
6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.
21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-005.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 students, we noted the following:
6 disbursement dates were incorrectly reported to the COD
3 disbursement amounts were incorrectly reported to the COD
10 disbursements were not reported to the COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 students, we noted the following:
6 disbursement dates were incorrectly reported to the COD
3 disbursement amounts were incorrectly reported to the COD
10 disbursements were not reported to the COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: American Rescue Plan (ARP) created two new requirements that a portion of Higher Education Emergency Relief Fund (HEERF) III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act.
Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP.
Condition: During our testing, it was noted the University did not spend any funds on direct outreach to financial aid applicants, as outlined per the terms of the agreement.
Questioned costs: None.
Context: While testing reporting and earmarking requirements, we noted that there were no funds spent on direct outreach to financial aid applicants.
Cause: The University was not aware of all the earmarking requirements.
Effect: The University is not in compliance with all provisions of the grant agreement.
Repeat finding: No.
Recommendation: We recommend the University implement a process to ensure all grant agreements are reviewed and there is a clear understanding of any reporting and/or earmarking requirements to limit the risk of noncompliance.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: American Rescue Plan (ARP) created two new requirements that a portion of Higher Education Emergency Relief Fund (HEERF) III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act.
Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP.
Condition: During our testing, it was noted the University did not spend any funds on direct outreach to financial aid applicants, as outlined per the terms of the agreement.
Questioned costs: None.
Context: While testing reporting and earmarking requirements, we noted that there were no funds spent on direct outreach to financial aid applicants.
Cause: The University was not aware of all the earmarking requirements.
Effect: The University is not in compliance with all provisions of the grant agreement.
Repeat finding: No.
Recommendation: We recommend the University implement a process to ensure all grant agreements are reviewed and there is a clear understanding of any reporting and/or earmarking requirements to limit the risk of noncompliance.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM
Achievement
Assistance Listing Number: 84.031C
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and (3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. (CFR 200.405)
Condition: During testing of indirect costs, it was noted that the University did not properly calculate the allocation of indirect costs.
Questioned costs: $15,710.
Context: During our testing, it was noted that the University used the budgeted amount of indirect costs from the grant agreement instead of calculating the indirect costs based on actual direct costs incurred multiplied by the University’s negotiated indirect cost rate. It was also noted that the grant period for year 1 was October 1, 2021 through September 30, 2022 and that majority of indirect costs for that period were claimed in fiscal year 2023 instead of as the direct costs were incurred.
Cause: By utilizing the budgeted amount instead of calculating the indirect costs for the period based off actual expenditures, $15,170 of indirect costs were claimed that should not have been.
Effect: The University is not in compliance with allowable cost principles.
Repeat finding: No.
Recommendation: We recommend the University calculate the indirect costs when the direct cost is incurred instead of claiming the amount per the budget to ensure indirect costs are consistently calculated and allocated throughout the grant term.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.425L, 84.031C
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2022-003 for 84.425L only.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.425L, 84.031C
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2022-003 for 84.425L only.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Questioned costs: None.
Context: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Cause: The University does not have formal procedures in place for reviewing calculations for funds to be drawn and reports prior to submission.
Effect: When separation of duties is inadequate, there is an increased risk that errors can occur and not be detected.
Repeat finding: Yes, 2022-004.
Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Questioned costs: None.
Context: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests.
Cause: The University does not have formal procedures in place for reviewing calculations for funds to be drawn and reports prior to submission.
Effect: When separation of duties is inadequate, there is an increased risk that errors can occur and not be detected.
Repeat finding: Yes, 2022-004.
Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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 of enrollment information at both the program and campus-level detail, we noted the following:
15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status
17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records
25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner
1 out of 40 students’ published program lengths reported to the NSLDS was not correct
6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.
21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-005.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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 of enrollment information at both the program and campus-level detail, we noted the following:
15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status
17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records
25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner
1 out of 40 students’ published program lengths reported to the NSLDS was not correct
6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.
21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-005.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 students, we noted the following:
6 disbursement dates were incorrectly reported to the COD
3 disbursement amounts were incorrectly reported to the COD
10 disbursements were not reported to the COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 students, we noted the following:
6 disbursement dates were incorrectly reported to the COD
3 disbursement amounts were incorrectly reported to the COD
10 disbursements were not reported to the COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days.
Questioned costs: $13,996.
Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days.
Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: American Rescue Plan (ARP) created two new requirements that a portion of Higher Education Emergency Relief Fund (HEERF) III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act.
Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP.
Condition: During our testing, it was noted the University did not spend any funds on direct outreach to financial aid applicants, as outlined per the terms of the agreement.
Questioned costs: None.
Context: While testing reporting and earmarking requirements, we noted that there were no funds spent on direct outreach to financial aid applicants.
Cause: The University was not aware of all the earmarking requirements.
Effect: The University is not in compliance with all provisions of the grant agreement.
Repeat finding: No.
Recommendation: We recommend the University implement a process to ensure all grant agreements are reviewed and there is a clear understanding of any reporting and/or earmarking requirements to limit the risk of noncompliance.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Portion, and Minority Serving Institutions
Assistance Listing Number: 84.425E and 84.425L
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: American Rescue Plan (ARP) created two new requirements that a portion of Higher Education Emergency Relief Fund (HEERF) III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act.
Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP.
Condition: During our testing, it was noted the University did not spend any funds on direct outreach to financial aid applicants, as outlined per the terms of the agreement.
Questioned costs: None.
Context: While testing reporting and earmarking requirements, we noted that there were no funds spent on direct outreach to financial aid applicants.
Cause: The University was not aware of all the earmarking requirements.
Effect: The University is not in compliance with all provisions of the grant agreement.
Repeat finding: No.
Recommendation: We recommend the University implement a process to ensure all grant agreements are reviewed and there is a clear understanding of any reporting and/or earmarking requirements to limit the risk of noncompliance.
Views of responsible officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM
Achievement
Assistance Listing Number: 84.031C
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and (3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. (CFR 200.405)
Condition: During testing of indirect costs, it was noted that the University did not properly calculate the allocation of indirect costs.
Questioned costs: $15,710.
Context: During our testing, it was noted that the University used the budgeted amount of indirect costs from the grant agreement instead of calculating the indirect costs based on actual direct costs incurred multiplied by the University’s negotiated indirect cost rate. It was also noted that the grant period for year 1 was October 1, 2021 through September 30, 2022 and that majority of indirect costs for that period were claimed in fiscal year 2023 instead of as the direct costs were incurred.
Cause: By utilizing the budgeted amount instead of calculating the indirect costs for the period based off actual expenditures, $15,170 of indirect costs were claimed that should not have been.
Effect: The University is not in compliance with allowable cost principles.
Repeat finding: No.
Recommendation: We recommend the University calculate the indirect costs when the direct cost is incurred instead of claiming the amount per the budget to ensure indirect costs are consistently calculated and allocated throughout the grant term.
Views of responsible officials: Management agrees with the finding.