Audit 302079

FY End
2023-06-30
Total Expended
$27.50M
Findings
8
Programs
28
Organization: Dillard University (LA)
Year: 2023 Accepted: 2024-04-01

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
391640 2023-001 Material Weakness Yes N
391641 2023-001 Material Weakness Yes N
391642 2023-001 Material Weakness Yes N
391643 2023-002 Material Weakness - E
968082 2023-001 Material Weakness Yes N
968083 2023-001 Material Weakness Yes N
968084 2023-001 Material Weakness Yes N
968085 2023-002 Material Weakness - E

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $10.19M Yes 2
84.063 Federal Pell Grant Program $4.68M Yes 1
84.031 Higher Education_institutional Aid $3.66M - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.21M Yes 0
84.425 Education Stabilization Fund $863,409 Yes 0
12.630 Basic, Applied, and Advanced Research in Science and Engineering $508,029 Yes 0
84.033 Federal Work-Study Program $391,327 Yes 0
84.044 Trio_talent Search $367,280 - 0
84.007 Federal Supplemental Educational Opportunity Grants $325,203 Yes 1
12.800 Air Force Defense Research Sciences Program $212,898 Yes 0
93.859 Biomedical Research and Research Training $147,140 Yes 0
84.217 Trio_mcnair Post-Baccalaureate Achievement $140,002 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $137,552 Yes 0
84.120 Minority Science and Engineering Improvement $136,740 - 0
84.042 Trio_student Support Services $114,406 - 0
93.368 21st Century Cures Act - Precision Medicine Initiative $106,219 Yes 0
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $79,358 - 0
93.364 Nursing Student Loans $68,950 Yes 0
43.008 Education $55,633 Yes 0
47.050 Geosciences $46,599 Yes 0
47.075 Social, Behavioral, and Economic Sciences $38,877 Yes 0
81.049 Office of Science Financial Assistance Program $24,004 - 0
47.070 Computer and Information Science and Engineering $12,052 Yes 0
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $9,983 - 0
47.076 Education and Human Resources $8,571 Yes 0
19.009 Academic Exchange Programs - Undergraduate Programs $7,143 - 0
93.307 Minority Health and Health Disparities Research $5,900 Yes 0
43.001 Science $3,511 Yes 0

Contacts

Name Title Type
FR9LM1J86MJ5 Wanda Brooks Auditee
5048164039 Sean M Bruno Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - General Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. Dillard University (the University) located in New Orleans, Louisiana is an institution of higher education founded in 1869. The University is a private, historically black liberal arts college that is affiliated with the United Church of Christ and the United Methodist Church, with degree-granting academic units which include the following: -- School of Accounting and Financial Economics; -- School of Population and Health Sciences; -- School of Humanities; -- School of Science, Technology, Engineering and Math; -- School of Social Sciences; -- School of Business Administration; and -- College of Nursing. The University is accredited by the Commission on Colleges of the Southern Association of Colleges and Schools. Dillard University is the recipient of various Federal grants, subgrants and awards from the U.S. Department of Defense, U.S. Department of Education, the U.S. Department of Health and Human Services, U.S. Department of Homeland Security, U.S. Department of Housing and Urban Development, and other agencies to assist in achieving a higher level of learning for its student body. Total direct federal and federal awards passed through other agencies amounted to more than $27,501,403 for the fiscal year July 1, 2022 through June 30, 2023. Student Financial Aid Dillard University was approved by the then Office of Education for participation in the Student Financial Aid Programs. These programs include the Nursing Student Loan Program (NSL), Federal Work Study Program (FWS), Federal Supplemental Education Opportunity Grant Program (FSEOG), Federal PELL Grant and the Federal Direct Student Loan Program (Direct). Listed below is a brief description of the Student Aid Programs administered by the University. The authority for schools to make new Federal Perkins Loans ended September 30, 2017. o Nursing Student Loan Program The University entered into an agreement with the U.S. Department of Health and Human Services to establish a Nursing Student Loan Program. During the year ended June 30, 2023, $68,950 in Nursing Student Loans were disbursed to students. o Federal Work-Study Program The University established the FWS Program pursuant to Title IV, Part C of the Higher Education Act of 1965, as amended. During the year ended June 30, 2023, federal expenditures totaled $391,327. The University elected and received approval from the U.S. Department of Education to waive the institutional matching requirement for the Federal Work Study Program's approved funding level for the fiscal year ended June 30, 2023. The University was entitled to this waiver because of its participation in the Strengthening Historically Black Colleges Title III Program. o FSEOG Program The FSEOG Program was established at the University in 1965 under Title IV, Part A of the Higher Education Act of 1965, as amended. During the year ended June 30, 2023, federal expenditures totaled $325,203. The University received approval from the U.S. Department of Education to waive the institutional matching requirement for the FSEOG Program. o Federal Pell Grant Program The University entered into an agreement with the Office of Education to participate in the Federal Pell Grant Program. This program provides eligible students with a foundation of financial aid to help defray the costs of post-secondary education. During the year ended June 30, 2023, Federal Pell Grant awards to full-time and part-time students totaled $4,682,621. o Federal Direct Student Loan Program The Federal Direct Student Loan Program enables eligible undergraduate and graduate students to borrow directly from a bank or other lending institution. During the current year, approximately $10,193,312 was disbursed to students under the Federal Direct Student Loan Program. The Federal Direct Student Loan Program's Cohort default rate is 0.0%. The Student Financial Aid programs are administered by the University’s Financial Aid Department. All accounting for the Student Financial Aid programs is performed by the University’s Division of Business and Finance. The Financial Aid office is under the control of the Vice-President of Business and Finance.
Title: Note 2 - Basis of Presentation and Accounting Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards includes the federal award activity of the University under programs of the federal government for the year ended June 30, 2023. The information in the Schedule of Expenditures of Federal Awards is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the activities of the University, it is not intended to and does not present either the financial position, changes in net assets, cash flows or the current fund's revenues, expenditures, and other changes of the University. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. The purpose of the Schedule of Expenditures of Federal Awards is to present a summary of those activities of the University for the year ended June 30, 2023 which have been financed principally by the U. S. Government (federal awards). For purposes of the Schedule, federal awards include all Federal assistance and procurement relationships entered into directly between the University and the federal government and sub-awards from non-federal organizations made under federally sponsored agreements.
Title: Note 3 - Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement.
Title: Note 4 - Program Organization and Financing - (Nursing Loan Program) Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The Nursing Loan Program is operated by the University under an agreement with the Department of Health and Human Services. The accounts of the program are included among the Loan Funds of the University. The University disbursed Nursing loans to students totaling $68,950.
Title: Note 5 - Contingencies Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. Participation in Grant Programs The University administers and participates in certain federal and state programs as disclosed in the Schedule of Expenditures of Federal Awards. In connection with the administration and operations of these grants, the University is to expend grant funds and allocations in accordance with program guidelines and regulations. However, should the University have operated or administered the programs and/or grants in a manner which would be in non-compliance with the guidelines and regulations, the University may be required by the funding sources to repay some portion or all of the grant award.
Title: Note 6 - Major Federal Financial Assistance Programs Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The University’s major federal financial assistance program for the year ended June 30, 2023 was determined based on guidelines established by the Uniform Guidance. Such programs are the Student Financial Assistance Cluster, Educational Stabilization Fund (CARES Act), Research and Development Cluster, and Disaster Grants-Public Assistance (Presidentially Declared Disasters).
Title: Note 7 - Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance.
Title: Note 8 - Subrecipients Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. Of the federal expenditures presented in the Schedule, the University did not provide federal awards to sub recipients.
Title: Note 9 - Loans and Loan Guarantees Outstanding and Other Non-Cash Assistance Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The federal student loan programs are administered directly by the University, and balances and transactions relating to these programs are included in the University’s basic financial statements. Loans made during the year are included in the federal expenditures presented in the Schedule of Expenditures of Federal Awards. The Schedule of Expenditures of Federal Awards and the related notes include certain loans and loan guarantees outstanding as well as non-cash assistance as presented in the Schedule I, Schedule of Disclosures for Federally Assisted Loans. Outstanding loan balances are only presented for those programs with significant compliance requirements other than repayment.
Title: Note 10 - Subrequent Events Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. The University has evaluated subsequent events from July 1, 2023 to March 29, 2024 the date the financial statements were available to be issued and determined that no events occurred that required disclosure. No subsequent events occurring after this date have been evaluated for inclusion in these financial statements.
Title: Note 11 - Financial Responsibility Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards is presented on the same basis of accounting as the financial statements, although the basis for determining when federal awards are expensed is presented in accordance with the Uniform Guidance . Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowed or are limited as tor reimbursement. De Minimis Rate Used: N Rate Explanation: The University has not elected to use the ten percent (10%) de minimis indirect cost rate allowed under the Uniform Guidance. Section 498(c)(1) of the Higher Education Act authorizes the Secretary of the Department to establish ratios and other criteria for determining whether an institution has sufficient financial responsibility. Section 668.172 of the current regulation, originally effective July 1, 1998, established a methodology based on three (3) ratios—primary reserve, equity, and net income—that measure different aspects of financial health and are combined into a composite score to measure financial responsibility. Several mathematical steps are required to combine an institution's ratio results into a composite score: • Determine the value of each ratio; • Calculate a strength factor score for each ratio using the appropriate algorithm; • Calculate a weighted score for each ratio by multiplying the strength factor score by its corresponding weighted percentage; and • Add the weighted scores to arrive at the composite score. Institutions receiving a composite score of 1.5 or greater are considered financially responsible. An institution that fails the financial responsibility standards may continue to participate in the Title IV programs under provisional certification for three (3) years. To continue to participate in the Title IV programs under provisional certification, an institution will be required to provide surety to the Department of Education of ten (10) percent or more of its previous year’s Title IV funding, as determined by the Department of Education. The University included the debt obtained through long-term lines of credit in total debt obtained for long-term purposes that exceeds 12 months and was used to fund capitalized assets (i.e., property, plant and equipment). See the Notes to the SEFA for chart/table.

Finding Details

Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Cost 2023-002 – Annual and Aggregate Loan Limits $6,769 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations, 34 CFR 685.203 (a) stipulates annual loan limits based upon the undergraduate student’s completed years of program of undergraduate education. The annual loan limit for a student who has not completed the 1st year of study is $3,500, 2nd year of study is $4,500 and remainder of the program is $5,500. Title IV regulations, 34 CFR 685.203 (b) stipulates that a dependent student may receive an additional unsubsidized loan in the amount of $2,000. Students whose parents are likely to be precluded by exceptional circumstances from receiving a PLUS loan may be eligible for an unsubsidized loan beyond the base amount of $2,000. CFR 685.203(d) stipulates the aggregate unpaid principal amount of all Direct subsidized loans made to a student but excluding the amount of capitalized interest may not exceed (1) $23,000 in the case of any student who has not successfully completed a program of study at the undergraduate level and (2) $65,500 in the case of a graduate or professional student, including loans for undergraduate study. The total amount of Direct unsubsidized loans but excluding the amount of capitalized interest may not exceed (1) for a dependent undergraduate student, $23000, or, effective July 1, 2008, $31,000, minus any Direct subsidized loan, and (2) for an independent undergraduate or a dependent undergraduate who qualifies for additional eligibility, $57,500, minus any Direct subsidized loan. Conditions and Context I noted during my audit: • two (2) students out of twenty-five (25) tested received direct loans in excess of the aggregate loan limit totaling $3,803, and • three (3) students out of twenty-one (21) tested who received subsidized loans in excess of the annual loan limit totaling $2,966. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Cause It appears that the University did not ensure that the student was eligible to receive the loan proceeds. Questioned Costs For the purposes of this condition, I have questioned costs totaling $6,769 related to the Direct loan program. Effect The University has not adhered to Title IV regulations regarding the disbursing of loan funds in accordance with the regulations. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Repeat Finding No.   Management’s Response The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled, and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring, which has been discussed as preparation for bringing up a new system.
Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.
Audit Finding Reference Number Questioned Cost 2023-002 – Annual and Aggregate Loan Limits $6,769 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations, 34 CFR 685.203 (a) stipulates annual loan limits based upon the undergraduate student’s completed years of program of undergraduate education. The annual loan limit for a student who has not completed the 1st year of study is $3,500, 2nd year of study is $4,500 and remainder of the program is $5,500. Title IV regulations, 34 CFR 685.203 (b) stipulates that a dependent student may receive an additional unsubsidized loan in the amount of $2,000. Students whose parents are likely to be precluded by exceptional circumstances from receiving a PLUS loan may be eligible for an unsubsidized loan beyond the base amount of $2,000. CFR 685.203(d) stipulates the aggregate unpaid principal amount of all Direct subsidized loans made to a student but excluding the amount of capitalized interest may not exceed (1) $23,000 in the case of any student who has not successfully completed a program of study at the undergraduate level and (2) $65,500 in the case of a graduate or professional student, including loans for undergraduate study. The total amount of Direct unsubsidized loans but excluding the amount of capitalized interest may not exceed (1) for a dependent undergraduate student, $23000, or, effective July 1, 2008, $31,000, minus any Direct subsidized loan, and (2) for an independent undergraduate or a dependent undergraduate who qualifies for additional eligibility, $57,500, minus any Direct subsidized loan. Conditions and Context I noted during my audit: • two (2) students out of twenty-five (25) tested received direct loans in excess of the aggregate loan limit totaling $3,803, and • three (3) students out of twenty-one (21) tested who received subsidized loans in excess of the annual loan limit totaling $2,966. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Cause It appears that the University did not ensure that the student was eligible to receive the loan proceeds. Questioned Costs For the purposes of this condition, I have questioned costs totaling $6,769 related to the Direct loan program. Effect The University has not adhered to Title IV regulations regarding the disbursing of loan funds in accordance with the regulations. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Repeat Finding No.   Management’s Response The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled, and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring, which has been discussed as preparation for bringing up a new system.