Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Exit Counseling Notification for Withdrawn Students
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.304(b)(3) - If a student borrower withdraws from
school, exit counseling must be provided either electronically, by mailing, or by email to the student
borrower within 30 days.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, the
University was unable to provide evidence of exit counseling notifications being sent to 4 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure exit counseling notifications were
sent to withdrawn students timely.
Effect: The University is not in compliance with Title 34, Section 685.304 with respect to the
referenced withdrawn students.
Recommendation: We recommend that the University establish controls to ensure that exit
counseling notifications are sent timely once a student has been identified as a withdrawal.
Incomplete Summary Level Report of Title IV Funds Not Returned
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: CARES Act Section 3508(2) - The Secretary shall require each
institution using a waiver relating to the withdrawal of recipients to report the number of such
recipients, the amount of grant or loan assistance associated with each such recipient, and the total
amount of grant or loan assistance for which each institution has not returned assistance under title
IV to the Secretary.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, 1
student was not included in the Summary Level Report of Title IV Funds not returned.
Questioned Cost: $-0-
Cause: There was not a procedure in place to verify that all students who withdrew from the
University after attending less than 60% of the enrollment period were included in the Summary
Level Report.
Effect: The number of recipients and total amount of assistance included in the Summary Level
Report was understated.
Recommendation: We recommend the University develop a procedure for verifying that all
withdrawn students are included in the Summary Level Report to ensure accurate reporting to the
Department.
NSLDS Notification of Withdrawn Status
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.309 - Unless the school expects to submit its next
enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30
days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled
on at least a half-time basis. The school is responsible for timely reporting whether they report
directly or via a third-party servicer.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, the
University failed to correctly notify NSLDS of 1 student’s status change.
Questioned Cost: $-0-
Cause: The University relied on their third-party servicer for reporting and did not have a control in
place to ensure that timely reporting of all status changes to NSLDS was occurring.
Effect: Without notification, the NSLDS is not timely updated of change in status for students who
have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student
enters repayment status.
Recommendation: We recommend that the University establish controls to review the reporting
function of their third-party servicer to ensure student enrollment status in the NSLDS is updated in a
timely manner in compliance with federal requirements.
Exit Counseling Notification for Graduated Students
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.304(b)(1) - A school must ensure that exit counseling is
conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or
professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least
half-time study at the school.
Condition: Out of a population of 118 graduated students, we sampled 16. Out of this sample, the
University was unable to provide evidence of exit counseling notifications being sent to 15 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure exit counseling notifications were
sent to graduating students timely.
Effect: The University is not in compliance with Title 34, Section 685.304 with respect to the
referenced graduated students.
Recommendation: We recommend that the University establish controls to ensure that exit
counseling notifications are sent prior to the date of graduation.
NSLDS Notification of Graduated Status
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.309 - Unless the school expects to submit its next
enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30
days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled
on at least a half-time basis. The school is responsible for timely reporting whether they report
directly or via a third-party servicer.
Condition: Out of a population of 118 graduated students, we sampled 16. Out of this sample, the
University failed to correctly notify NSLDS of 8 students’ status changes.
Questioned Cost: $-0-
Cause: The University relied on their third-party servicer for reporting and did not have a control in
place to ensure that timely reporting of all status changes to NSLDS was occurring.
Effect: Without notification, the NSLDS is not timely updated of change in status for students who
have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student
enters repayment status.
Recommendation: We recommend that the University establish controls to review the reporting
function of their third-party servicer to ensure student enrollment status in the NSLDS is updated in a
timely manner in compliance with federal requirements.
Right to Cancel Notifications
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.165(a)(2)(ii) - If an institution credits a student ledger
account with Direct Loan, or Federal Perkins Loan funds, the institution must notify the student or
parent of their right to cancel all or a portion of that loan, or loan disbursement.
Condition: Out of a population of 66 graduate students, we sampled 6. Out of this sample, the
University failed to provide evidence that right to cancel notifications were sent for all 6 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure right to cancel notifications were sent
to graduate students timely.
Effect: The University is not in compliance with Title 34, Section 668.165 with respect to graduate
students.
Recommendation: We recommend that the University establish controls to ensure that right to
cancel notifications are sent when student ledger accounts are credited.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
Lost Revenue
Information on the Federal Program: HEERF Institutional Portion (AL Number 84.425F) – U.S.
Department of Education
Criteria or specific requirement: 2 CFR Section 200.334 - Financial records, supporting documents,
statistical records, and all other non-federal entity records pertinent to a federal award must be
retained for a period of three years from the date of submission of the final expenditure report or,
for federal awards that are renewed quarterly or annually, from the date of the submission of the
quarterly or annual financial report, respectively, as reported to the federal awarding agency or passthrough
entity in the case of a subrecipient.
Higher Education Emergency Relief Fund Lost Revenue Frequently Asked Questions - An institution
must adequately document its estimate of lost revenue, including its rationale, calculations,
methodology, underlying data, and budgets or projections used to determine the amount of lost
revenue.
Condition: At the time the lost revenue estimation was made, the University did not
contemporaneously document its rationale, calculations, or methodology. Based on a review of
parking revenue data subsequently compiled from the previous four years, it was determined that
the amount reported as lost revenue in 2022 was reasonable; however, the contemporaneous record
retention criteria was not satisfied.
Questioned Cost: $-0-
Cause: The University did not retain contemporaneously prepared documentation supporting its
estimate of lost revenue including its rationale, calculations, and methodology.
Effect: Contemporaneously prepared documentation and justification of the lost revenue estimation
was not available to be audited. Historical parking revenue data from the previous four years was
subsequently compiled and provided to support the amount reported as lost revenue in 2022 was
reasonable.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure future documentation is created and retained in
accordance with specific grant requirements with an emphasis on the specific requirements of grants
new to the University.
Unidentifiable Federal Funds
Information on the Federal Program: Coronavirus State and Local Fiscal Recovery Funds (AL
Number 21.027) – U.S. Department of the Treasury
Criteria: 2 CFR 200.302 (b) (1) -The financial management system of each non-federal entity must
provide for the identification, in its accounts, of all federal awards received and expended and the
federal programs under which they were received. federal program and federal award identification
must include, as applicable, the Assistance Listings title and number, federal award identification
number and year, name of the federal agency, and name of the pass-through entity, if any.
Condition: Federal funds totaling $138,700 were not identified within the accounts of the
University’s financial management system. These funds were posted in a payment holding account
and were not identifiable as federal funds.
Questioned Cost: $-0-
Cause: The internal controls in place to ensure the identification of all federal payments received and
expended failed to identify the above funds as federal funds.
Effect: Without further investigation into the holding account, these funds would not have been
identifiable within the University’s financial management system and would have been excluded from
the Schedule of Expenditures of federal Awards.
Recommendation: We recommend the University review the controls in place to identify federal
funds and enhance if warranted.
SNAP-Ed Unallowable Expenditures
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.475(b) - Costs incurred by employees and officers for travel, including
costs of lodging, other subsistence, and incidental expenses, must be considered reasonable and
otherwise allowable only to the extent such costs do not exceed charges normally allowed by the
non-federal entity in its regular operations as the result of the non-federal entity's written travel
policy. In addition, if these costs are charged directly to the federal award then documentation must
justify that:
(1) Participation of the individual is necessary to the Federal award; and
(2) The costs are reasonable and consistent with non-Federal entity's established travel policy.
OMB Compliance Supplement 2023 - SNAP-Ed funds must be used for the administrative costs of
planning, implementing, operating, and evaluating a SNAP-Ed program in accordance with the
state’s approved SNAP-Ed Plan.
Guidance from the State of Kentucky regarding allowable costs restrictions on travel and conferences
is included in award number SC7362000001287 and SC362200001080.
Condition: The University expended $38,596 of SNAP-Ed funds for 27 employees to travel to the
annual Association of Administrators System-Wide Conference. We were only able to substantiate
allowable expense for 3 of these employees to costs related to the SNAP-Ed program. We were
unable to substantiate the travel cost for the other 24 employees as costs related to the SNAP-Ed
program through prior written approval from the pass-through entity.
Questioned Cost: $35,296
Cause: The University expended federal funds on travel that could not be substantiated, through
prior written approval from the pass-through entity, as allowable expenditures related to the SNAPEd
program.
Effect: The University is not in compliance with the allowable activities outlined by the pass-through
entity or provisions as outline in 2 CFR Section 200.475(b) of the Code of Federal Regulations.
Recommendation: We recommend the University ensure staff working with federal funds are
provided adequate training to understand the allowable requirements of federal programs.
Furthermore, the University should maintain records on approvals from the federal agencies or passthrough
agencies on all travel expenses and approvals in a centralized manner for maintains records
for the required amount of time.
SNAP-Ed Record Retention
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.334 - Financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to a Federal award must be retained for a period of three
years from the date of submission of the final expenditure report or, for Federal awards that are
renewed quarterly or annually, from the date of the submission of the quarterly or annual financial
report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of
a subrecipient.
State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the
University must submit monthly and quarterly reports to the DCBS Division of Family Support,
Director's office.
Condition: Monthly and quarterly reports required to be submitted by the University to the State
were not adequately retained during the required three-year period beginning July 1, 2021.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all required
reporting documents were retained during the specified three-year period.
Effect: Monthly and quarterly reporting for all periods were not available to be audited.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure documentation is created and retained in accordance with
federal and pass-through requirements.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
SNAP-Ed Unallowable Expenditures
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.475(b) - Costs incurred by employees and officers for travel, including
costs of lodging, other subsistence, and incidental expenses, must be considered reasonable and
otherwise allowable only to the extent such costs do not exceed charges normally allowed by the
non-federal entity in its regular operations as the result of the non-federal entity's written travel
policy. In addition, if these costs are charged directly to the federal award then documentation must
justify that:
(1) Participation of the individual is necessary to the Federal award; and
(2) The costs are reasonable and consistent with non-Federal entity's established travel policy.
OMB Compliance Supplement 2023 - SNAP-Ed funds must be used for the administrative costs of
planning, implementing, operating, and evaluating a SNAP-Ed program in accordance with the
state’s approved SNAP-Ed Plan.
Guidance from the State of Kentucky regarding allowable costs restrictions on travel and conferences
is included in award number SC7362000001287 and SC362200001080.
Condition: The University expended $38,596 of SNAP-Ed funds for 27 employees to travel to the
annual Association of Administrators System-Wide Conference. We were only able to substantiate
allowable expense for 3 of these employees to costs related to the SNAP-Ed program. We were
unable to substantiate the travel cost for the other 24 employees as costs related to the SNAP-Ed
program through prior written approval from the pass-through entity.
Questioned Cost: $35,296
Cause: The University expended federal funds on travel that could not be substantiated, through
prior written approval from the pass-through entity, as allowable expenditures related to the SNAPEd
program.
Effect: The University is not in compliance with the allowable activities outlined by the pass-through
entity or provisions as outline in 2 CFR Section 200.475(b) of the Code of Federal Regulations.
Recommendation: We recommend the University ensure staff working with federal funds are
provided adequate training to understand the allowable requirements of federal programs.
Furthermore, the University should maintain records on approvals from the federal agencies or passthrough
agencies on all travel expenses and approvals in a centralized manner for maintains records
for the required amount of time.
SNAP-Ed Record Retention
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.334 - Financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to a Federal award must be retained for a period of three
years from the date of submission of the final expenditure report or, for Federal awards that are
renewed quarterly or annually, from the date of the submission of the quarterly or annual financial
report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of
a subrecipient.
State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the
University must submit monthly and quarterly reports to the DCBS Division of Family Support,
Director's office.
Condition: Monthly and quarterly reports required to be submitted by the University to the State
were not adequately retained during the required three-year period beginning July 1, 2021.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all required
reporting documents were retained during the specified three-year period.
Effect: Monthly and quarterly reporting for all periods were not available to be audited.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure documentation is created and retained in accordance with
federal and pass-through requirements.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Exit Counseling Notification for Withdrawn Students
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.304(b)(3) - If a student borrower withdraws from
school, exit counseling must be provided either electronically, by mailing, or by email to the student
borrower within 30 days.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, the
University was unable to provide evidence of exit counseling notifications being sent to 4 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure exit counseling notifications were
sent to withdrawn students timely.
Effect: The University is not in compliance with Title 34, Section 685.304 with respect to the
referenced withdrawn students.
Recommendation: We recommend that the University establish controls to ensure that exit
counseling notifications are sent timely once a student has been identified as a withdrawal.
Incomplete Summary Level Report of Title IV Funds Not Returned
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: CARES Act Section 3508(2) - The Secretary shall require each
institution using a waiver relating to the withdrawal of recipients to report the number of such
recipients, the amount of grant or loan assistance associated with each such recipient, and the total
amount of grant or loan assistance for which each institution has not returned assistance under title
IV to the Secretary.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, 1
student was not included in the Summary Level Report of Title IV Funds not returned.
Questioned Cost: $-0-
Cause: There was not a procedure in place to verify that all students who withdrew from the
University after attending less than 60% of the enrollment period were included in the Summary
Level Report.
Effect: The number of recipients and total amount of assistance included in the Summary Level
Report was understated.
Recommendation: We recommend the University develop a procedure for verifying that all
withdrawn students are included in the Summary Level Report to ensure accurate reporting to the
Department.
NSLDS Notification of Withdrawn Status
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.309 - Unless the school expects to submit its next
enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30
days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled
on at least a half-time basis. The school is responsible for timely reporting whether they report
directly or via a third-party servicer.
Condition: Out of a population of 26 withdrawn students, we sampled 5. Out of this sample, the
University failed to correctly notify NSLDS of 1 student’s status change.
Questioned Cost: $-0-
Cause: The University relied on their third-party servicer for reporting and did not have a control in
place to ensure that timely reporting of all status changes to NSLDS was occurring.
Effect: Without notification, the NSLDS is not timely updated of change in status for students who
have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student
enters repayment status.
Recommendation: We recommend that the University establish controls to review the reporting
function of their third-party servicer to ensure student enrollment status in the NSLDS is updated in a
timely manner in compliance with federal requirements.
Exit Counseling Notification for Graduated Students
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.304(b)(1) - A school must ensure that exit counseling is
conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or
professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least
half-time study at the school.
Condition: Out of a population of 118 graduated students, we sampled 16. Out of this sample, the
University was unable to provide evidence of exit counseling notifications being sent to 15 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure exit counseling notifications were
sent to graduating students timely.
Effect: The University is not in compliance with Title 34, Section 685.304 with respect to the
referenced graduated students.
Recommendation: We recommend that the University establish controls to ensure that exit
counseling notifications are sent prior to the date of graduation.
NSLDS Notification of Graduated Status
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 685.309 - Unless the school expects to submit its next
enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30
days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled
on at least a half-time basis. The school is responsible for timely reporting whether they report
directly or via a third-party servicer.
Condition: Out of a population of 118 graduated students, we sampled 16. Out of this sample, the
University failed to correctly notify NSLDS of 8 students’ status changes.
Questioned Cost: $-0-
Cause: The University relied on their third-party servicer for reporting and did not have a control in
place to ensure that timely reporting of all status changes to NSLDS was occurring.
Effect: Without notification, the NSLDS is not timely updated of change in status for students who
have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student
enters repayment status.
Recommendation: We recommend that the University establish controls to review the reporting
function of their third-party servicer to ensure student enrollment status in the NSLDS is updated in a
timely manner in compliance with federal requirements.
Right to Cancel Notifications
Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) –
U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.165(a)(2)(ii) - If an institution credits a student ledger
account with Direct Loan, or Federal Perkins Loan funds, the institution must notify the student or
parent of their right to cancel all or a portion of that loan, or loan disbursement.
Condition: Out of a population of 66 graduate students, we sampled 6. Out of this sample, the
University failed to provide evidence that right to cancel notifications were sent for all 6 students.
Questioned Cost: $-0-
Cause: The University did not have a control in place to ensure right to cancel notifications were sent
to graduate students timely.
Effect: The University is not in compliance with Title 34, Section 668.165 with respect to graduate
students.
Recommendation: We recommend that the University establish controls to ensure that right to
cancel notifications are sent when student ledger accounts are credited.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
Lost Revenue
Information on the Federal Program: HEERF Institutional Portion (AL Number 84.425F) – U.S.
Department of Education
Criteria or specific requirement: 2 CFR Section 200.334 - Financial records, supporting documents,
statistical records, and all other non-federal entity records pertinent to a federal award must be
retained for a period of three years from the date of submission of the final expenditure report or,
for federal awards that are renewed quarterly or annually, from the date of the submission of the
quarterly or annual financial report, respectively, as reported to the federal awarding agency or passthrough
entity in the case of a subrecipient.
Higher Education Emergency Relief Fund Lost Revenue Frequently Asked Questions - An institution
must adequately document its estimate of lost revenue, including its rationale, calculations,
methodology, underlying data, and budgets or projections used to determine the amount of lost
revenue.
Condition: At the time the lost revenue estimation was made, the University did not
contemporaneously document its rationale, calculations, or methodology. Based on a review of
parking revenue data subsequently compiled from the previous four years, it was determined that
the amount reported as lost revenue in 2022 was reasonable; however, the contemporaneous record
retention criteria was not satisfied.
Questioned Cost: $-0-
Cause: The University did not retain contemporaneously prepared documentation supporting its
estimate of lost revenue including its rationale, calculations, and methodology.
Effect: Contemporaneously prepared documentation and justification of the lost revenue estimation
was not available to be audited. Historical parking revenue data from the previous four years was
subsequently compiled and provided to support the amount reported as lost revenue in 2022 was
reasonable.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure future documentation is created and retained in
accordance with specific grant requirements with an emphasis on the specific requirements of grants
new to the University.
Unidentifiable Federal Funds
Information on the Federal Program: Coronavirus State and Local Fiscal Recovery Funds (AL
Number 21.027) – U.S. Department of the Treasury
Criteria: 2 CFR 200.302 (b) (1) -The financial management system of each non-federal entity must
provide for the identification, in its accounts, of all federal awards received and expended and the
federal programs under which they were received. federal program and federal award identification
must include, as applicable, the Assistance Listings title and number, federal award identification
number and year, name of the federal agency, and name of the pass-through entity, if any.
Condition: Federal funds totaling $138,700 were not identified within the accounts of the
University’s financial management system. These funds were posted in a payment holding account
and were not identifiable as federal funds.
Questioned Cost: $-0-
Cause: The internal controls in place to ensure the identification of all federal payments received and
expended failed to identify the above funds as federal funds.
Effect: Without further investigation into the holding account, these funds would not have been
identifiable within the University’s financial management system and would have been excluded from
the Schedule of Expenditures of federal Awards.
Recommendation: We recommend the University review the controls in place to identify federal
funds and enhance if warranted.
SNAP-Ed Unallowable Expenditures
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.475(b) - Costs incurred by employees and officers for travel, including
costs of lodging, other subsistence, and incidental expenses, must be considered reasonable and
otherwise allowable only to the extent such costs do not exceed charges normally allowed by the
non-federal entity in its regular operations as the result of the non-federal entity's written travel
policy. In addition, if these costs are charged directly to the federal award then documentation must
justify that:
(1) Participation of the individual is necessary to the Federal award; and
(2) The costs are reasonable and consistent with non-Federal entity's established travel policy.
OMB Compliance Supplement 2023 - SNAP-Ed funds must be used for the administrative costs of
planning, implementing, operating, and evaluating a SNAP-Ed program in accordance with the
state’s approved SNAP-Ed Plan.
Guidance from the State of Kentucky regarding allowable costs restrictions on travel and conferences
is included in award number SC7362000001287 and SC362200001080.
Condition: The University expended $38,596 of SNAP-Ed funds for 27 employees to travel to the
annual Association of Administrators System-Wide Conference. We were only able to substantiate
allowable expense for 3 of these employees to costs related to the SNAP-Ed program. We were
unable to substantiate the travel cost for the other 24 employees as costs related to the SNAP-Ed
program through prior written approval from the pass-through entity.
Questioned Cost: $35,296
Cause: The University expended federal funds on travel that could not be substantiated, through
prior written approval from the pass-through entity, as allowable expenditures related to the SNAPEd
program.
Effect: The University is not in compliance with the allowable activities outlined by the pass-through
entity or provisions as outline in 2 CFR Section 200.475(b) of the Code of Federal Regulations.
Recommendation: We recommend the University ensure staff working with federal funds are
provided adequate training to understand the allowable requirements of federal programs.
Furthermore, the University should maintain records on approvals from the federal agencies or passthrough
agencies on all travel expenses and approvals in a centralized manner for maintains records
for the required amount of time.
SNAP-Ed Record Retention
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.334 - Financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to a Federal award must be retained for a period of three
years from the date of submission of the final expenditure report or, for Federal awards that are
renewed quarterly or annually, from the date of the submission of the quarterly or annual financial
report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of
a subrecipient.
State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the
University must submit monthly and quarterly reports to the DCBS Division of Family Support,
Director's office.
Condition: Monthly and quarterly reports required to be submitted by the University to the State
were not adequately retained during the required three-year period beginning July 1, 2021.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all required
reporting documents were retained during the specified three-year period.
Effect: Monthly and quarterly reporting for all periods were not available to be audited.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure documentation is created and retained in accordance with
federal and pass-through requirements.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Student Account Credit Balance Reimbursement
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.077) – U.S. Department of Education
Criteria or specific requirement: 34 CFR 668.164(h) - If a credit balance occurred on or before the
first day of class of a payment period, it must be paid directly to the student or parent within 14 days
of the first day of class. If a credit balance occurred after the first day of class of a payment period, it
must be paid directly to the student or parent within 14 days of the occurrence.
Condition: Out of a population of 1,623 students, we sampled 40. Out of this sample, the University
failed to reimburse student account credit balances timely for 5 students.
Questioned Cost: $10,456
Cause: The University did not have a control in place to ensure credit balances were refunded timely.
Effect: The University is not in compliance with Title 34, Section CFR 668.164 with respect to the
referenced students.
Recommendation: We recommend that the University establish controls to ensure that credit
balances are paid directly to the student or parent within 14 days of the first day of class or within 14
days of the occurrence of a credit balance.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Academic Probation Notifications
Information on the Federal Program: Student Financial Aid Cluster (AL Numbers 84.268, 84.063,
84.033, 84.379, 84.038, and 84.007) – U.S. Department of Education.
Criteria or specific requirement: 34 CFR 668.16(e)(9) - An institution must provide notification to
the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Out of a sample of 40 students, we identified 14 that did not meet Satisfactory Academic
Progress (SAP). Out of the 14, the University failed to timely notify 1 of the students of academic
probation status.
Questioned Cost: $-0-
Cause: The controls in place to ensure academic probation notifications are sent to students in a
timely manner appeared to fail for the student identified above.
Effect: The University is not in compliance with Title 34 Section 668.16 with respect to the students
referenced.
Recommendation: We recommend the University review the controls in place to ensure that
academic probationary notifications are sent out promptly and enhance the controls if warranted.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.
SNAP-Ed Unallowable Expenditures
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.475(b) - Costs incurred by employees and officers for travel, including
costs of lodging, other subsistence, and incidental expenses, must be considered reasonable and
otherwise allowable only to the extent such costs do not exceed charges normally allowed by the
non-federal entity in its regular operations as the result of the non-federal entity's written travel
policy. In addition, if these costs are charged directly to the federal award then documentation must
justify that:
(1) Participation of the individual is necessary to the Federal award; and
(2) The costs are reasonable and consistent with non-Federal entity's established travel policy.
OMB Compliance Supplement 2023 - SNAP-Ed funds must be used for the administrative costs of
planning, implementing, operating, and evaluating a SNAP-Ed program in accordance with the
state’s approved SNAP-Ed Plan.
Guidance from the State of Kentucky regarding allowable costs restrictions on travel and conferences
is included in award number SC7362000001287 and SC362200001080.
Condition: The University expended $38,596 of SNAP-Ed funds for 27 employees to travel to the
annual Association of Administrators System-Wide Conference. We were only able to substantiate
allowable expense for 3 of these employees to costs related to the SNAP-Ed program. We were
unable to substantiate the travel cost for the other 24 employees as costs related to the SNAP-Ed
program through prior written approval from the pass-through entity.
Questioned Cost: $35,296
Cause: The University expended federal funds on travel that could not be substantiated, through
prior written approval from the pass-through entity, as allowable expenditures related to the SNAPEd
program.
Effect: The University is not in compliance with the allowable activities outlined by the pass-through
entity or provisions as outline in 2 CFR Section 200.475(b) of the Code of Federal Regulations.
Recommendation: We recommend the University ensure staff working with federal funds are
provided adequate training to understand the allowable requirements of federal programs.
Furthermore, the University should maintain records on approvals from the federal agencies or passthrough
agencies on all travel expenses and approvals in a centralized manner for maintains records
for the required amount of time.
SNAP-Ed Record Retention
Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of
Agriculture
Criteria: 2 CFR Section 200.334 - Financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to a Federal award must be retained for a period of three
years from the date of submission of the final expenditure report or, for Federal awards that are
renewed quarterly or annually, from the date of the submission of the quarterly or annual financial
report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of
a subrecipient.
State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the
University must submit monthly and quarterly reports to the DCBS Division of Family Support,
Director's office.
Condition: Monthly and quarterly reports required to be submitted by the University to the State
were not adequately retained during the required three-year period beginning July 1, 2021.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all required
reporting documents were retained during the specified three-year period.
Effect: Monthly and quarterly reporting for all periods were not available to be audited.
Recommendation: We recommend the University review the internal controls over the
administration of federal funds to ensure documentation is created and retained in accordance with
federal and pass-through requirements.