Program Information:
Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions – Borrower Data Transmission and Reconciliation – Federal regulations require that the University submit Federal Direct Loan Program (“Direct Loan”) disbursement records for students to the Common Origination and Disbursement (“COD”) in an accurate and timely manner (no earlier than 7 days before and no later than 15 days after disbursement of funds).
Condition: During our testing of student disbursement records, we noted the following exceptions:
• For 1 of 40 students selected for Federal Direct Loan Program disbursement testing, the University did not report an accurate disbursement date within the COD system.
Cause: Administrative oversight with respect to accurate and timely reporting of federal awards.
Effect or Potential Effect: The University is not in compliance with COD reporting requirements.
Questioned Costs:
None.
Context: We tested a sample of 40 students and found an exception as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University ensure that Direct Loan and Pell grant disbursement dates are entered into the COD website no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days after payment or the University becomes aware of the need to make an adjustment. Internal controls will be maintained by reporting on a daily basis as disbursements are posted. It should be noted that 1 out of 40 students is below the 5% threshold of error set forth by the United States Department of Education.
Program Information:
Federal Work-Study Program (“FWS”) (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): A. Activities Allowed and Unallowed/L. Reporting - An institution may carry forward and expend in the next award year up to 10% of the sum of its initial and supplemental FWS allocations for the current award year (34 CFR 675.18(b)).
Condition: During our testing of the University’s FWS expenditures, we noted that the University carried forward more than the allowable 10% of its FWS allocation into the subsequent award year and did not submit the reallocation form to the Department of Education prior to the submission of the University’s Fiscal Operations Report and Application to Participate (“FISAP”).
Cause: Administrative oversight with respect to accurate administration and disbursement of FWS awards.
Effect or Potential Effect: The University is not in compliance with FWS requirements.
Questioned Costs:
None.
Context: We tested the University’s compliance with FWS carry forward requirements and identified that the University exceeded the allowable 10% FWS carry forward threshold without obtaining the appropriate approvals from the Department of Education.
Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance is policies and procedures related to the accurate administration and disbursement of FWS awards to ensure that the appropriate approval is obtained prior to the carry forward of amounts that exceed the allowable threshold.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 3 of 25 students selected for testing, the University failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 5 of 25 students selected for testing, the University did not accurately report the student’s enrollment status.
• Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context:
We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. This action is completed through a third-party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 3 of 25 students selected for testing, the University failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 5 of 25 students selected for testing, the University did not accurately report the student’s enrollment status.
• Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context:
We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. This action is completed through a third-party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner.
Federal Program Information:
Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management – Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause: Administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs: None.
Context: We examined all draws of Federal Direct Loan Program funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification as a Repeat Finding: No similar finding was identified during the prior year.
Recommendation: We recommend that the University enhance its policies and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials
and Planned Corrective Actions: The University concurs with the finding. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information:
Title III Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition: During our testing of Title III equipment, we noted the following exceptions:
• The University was unable to provide documentation supporting the completion of a physical inventory of all equipment and real property purchased with federal funds during the most recent two fiscal years.
Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management.
Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management.
Questioned Costs:
None.
Context: The University was unable to provide documentation supporting the completion of a physical inventory of all equipment and real property purchased with federal funds during the most recent two fiscal years.
Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with the finding. The University has internal controls to ensure all federally funded equipment is tagged and tracked in compliance with the most up to date Federal Regulation. Additionally, this equipment is physically inventoried regularly but there is not a documented process to track when and how that happens. Moving forward, the Office of Sponsored Programs will work with Finance and Administration to establish an internal process to document the completion of the required physical inventory for all equipment and real property purchased with federal funds.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information:
Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions – Borrower Data Transmission and Reconciliation – Federal regulations require that the University submit Federal Direct Loan Program (“Direct Loan”) disbursement records for students to the Common Origination and Disbursement (“COD”) in an accurate and timely manner (no earlier than 7 days before and no later than 15 days after disbursement of funds).
Condition: During our testing of student disbursement records, we noted the following exceptions:
• For 1 of 40 students selected for Federal Direct Loan Program disbursement testing, the University did not report an accurate disbursement date within the COD system.
Cause: Administrative oversight with respect to accurate and timely reporting of federal awards.
Effect or Potential Effect: The University is not in compliance with COD reporting requirements.
Questioned Costs:
None.
Context: We tested a sample of 40 students and found an exception as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University ensure that Direct Loan and Pell grant disbursement dates are entered into the COD website no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days after payment or the University becomes aware of the need to make an adjustment. Internal controls will be maintained by reporting on a daily basis as disbursements are posted. It should be noted that 1 out of 40 students is below the 5% threshold of error set forth by the United States Department of Education.
Program Information:
Federal Work-Study Program (“FWS”) (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): A. Activities Allowed and Unallowed/L. Reporting - An institution may carry forward and expend in the next award year up to 10% of the sum of its initial and supplemental FWS allocations for the current award year (34 CFR 675.18(b)).
Condition: During our testing of the University’s FWS expenditures, we noted that the University carried forward more than the allowable 10% of its FWS allocation into the subsequent award year and did not submit the reallocation form to the Department of Education prior to the submission of the University’s Fiscal Operations Report and Application to Participate (“FISAP”).
Cause: Administrative oversight with respect to accurate administration and disbursement of FWS awards.
Effect or Potential Effect: The University is not in compliance with FWS requirements.
Questioned Costs:
None.
Context: We tested the University’s compliance with FWS carry forward requirements and identified that the University exceeded the allowable 10% FWS carry forward threshold without obtaining the appropriate approvals from the Department of Education.
Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance is policies and procedures related to the accurate administration and disbursement of FWS awards to ensure that the appropriate approval is obtained prior to the carry forward of amounts that exceed the allowable threshold.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 3 of 25 students selected for testing, the University failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 5 of 25 students selected for testing, the University did not accurately report the student’s enrollment status.
• Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context:
We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. This action is completed through a third-party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 3 of 25 students selected for testing, the University failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 5 of 25 students selected for testing, the University did not accurately report the student’s enrollment status.
• Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context:
We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. This action is completed through a third-party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner.
Federal Program Information:
Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management – Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause: Administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs: None.
Context: We examined all draws of Federal Direct Loan Program funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification as a Repeat Finding: No similar finding was identified during the prior year.
Recommendation: We recommend that the University enhance its policies and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials
and Planned Corrective Actions: The University concurs with the finding. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information:
Title III Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition: During our testing of Title III equipment, we noted the following exceptions:
• The University was unable to provide documentation supporting the completion of a physical inventory of all equipment and real property purchased with federal funds during the most recent two fiscal years.
Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management.
Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management.
Questioned Costs:
None.
Context: The University was unable to provide documentation supporting the completion of a physical inventory of all equipment and real property purchased with federal funds during the most recent two fiscal years.
Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements.
Views of Responsible Officials and Planned Corrective Actions:
The University concurs with the finding. The University has internal controls to ensure all federally funded equipment is tagged and tracked in compliance with the most up to date Federal Regulation. Additionally, this equipment is physically inventoried regularly but there is not a documented process to track when and how that happens. Moving forward, the Office of Sponsored Programs will work with Finance and Administration to establish an internal process to document the completion of the required physical inventory for all equipment and real property purchased with federal funds.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.
Program Information: Student Financial Assistance Cluster (ALN: Various) and Title III Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients of federal funding to complete audits and submit the data collection form and financial statement reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period.
Condition: The University did not submit the June 30, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the required deadline.
Cause: Insufficient internal controls and lack of administrative oversight with respect to timely financial statement reporting and appropriate documentation retention that is needed to complete the University’s financial statement audit and Single Audit within the required timeframe.
Effect or Potential Effect: The University is not in compliance with Single Audit reporting deadlines.
Questioned Costs: None.
Context: The University did not submit the June 30, 2023 Single Audit reporting package within the required timeframe.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that financial statement reporting is completed timely and appropriate documentation retention is maintained in order to complete financial and compliance audits within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline.