Finding 2023-013 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Finding 2023-014 – C. Cash Management
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs.
Condition – The University was unable to reconcile amounts drawn with amounts expended; the total amount drawn exceeded the amount expended for the fiscal year.
Certain program funds were also moved out the bank account used for federal draws and comingled with nonfederal dollars in the University’s operating bank account which resulted in a portion of the funds being used for non-program purposes. Upon identifying this issue, the University subsequent repaid the funds back, however this did not occur in a timely fashion.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cash management requirements.
Questioned Costs – None.
Context – For 4 of 6 drawdowns selected for testing, the University was unable to reconcile the amounts drawn with the amounts expended to evidence that the funds were used in a timely manner.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that documentation supporting its draws is retained and that time elapsed between transfer and disbursement of federal funds is minimized. We also recommend that the University enhances its internal controls to ensure funds are not comingled with non-program funds to prevent program funds from being used for non-program purposes.
Views of Responsible Officials – The University acknowledges that the internal controls surrounding the cash management of the Federal Research and Development Programs was not in compliance for federal standards. The University is in the process of enhancing the internal controls and cash management procedures to prevent this from happening in the future. Going forward all federal grant funds that are allocated for the Challenger Learning Center will go directly into the appropriate bank account and will be drawn down and spent in the correct time frame. When operating expenses are incurred for the Challenger Learning Center the payment will be processed from the University’s general checking and the federal grant funds will reimburse the University that day. The same is also true for the payroll expenses incurred by the Challenger Learning Center. Wages will be paid out of the university’s general checking account and then reimbursed to the university from the bank account that hold the federal grant funds.
Finding 2023-015 – B. Allowable Costs/Cost Principles – Indirect costs
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009)
Criteria or Specific Requirement – NASA’s Grant and Cooperative Agreement Manual indicates that if a recipient is applying an indirect cost rate to their NASA award, the indirect cost rate must be applied on the basis of the award’s modified total direct cost (“MTDC”), which includes direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000.
Condition – The University did not accurately calculate indirect costs.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cost principles.
Questioned Costs – Below reportable threshold.
Context – The University erroneously charged indirect costs to the grant for equipment/capital expenditures.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that indirect costs are charged accordingly.
Views of Responsible Officials – The University acknowledges that the allowable indirect costs reimbursed to the University from the NASA federal grant funds was not calculated correctly for fiscal year 2023. In recent years the University has applied for a quarterly no cost extension of the previously used indirect cost rate for federal grant purposes. In March of 2024 the University actively pursued a contract with a firm known as Point Consulting to help reevaluate the currently used in direct cost rate for the University. Pont consulting has been contracted by the university in past years, but the percentage has been simply rolled forward and not adjusted. Going forward the University plans to reevaluate the indirect cost percentage in accordance with federal guidelines. The accounting department will work directly with the Challenger Learning center to make sure that indirect funds are calculated correctly and drawn down in timely and accurate manner.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-008 – N. Special Tests and Provisions – Perkins Loan Record Keeping and Record Retention
Information on Federal Program(s) - Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement - Institutions must retain original or true and exact copies of promissory and master promissory notes, repayment records, and cancellation and deferment requests for each Federal Perkins Loan Program (“Perkins”) loan made.
Condition – For certain Perkins loans, the University could not locate the original promissory notes that contained all the necessary information, including signatures.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Perkins loan recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 21 of 40 students tested, the University was unable to provide documentation evidencing proper retention of loan records.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to prevent over Perkins loan recordkeeping and record retention requirements.
Views of Responsible Officials – Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information.
The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-004 – C. Cash Management
Information on Federal Program(s) - Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement - 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 – An instance was identified where funds drawn were held in excess of the allowable time frame.
Cause - Administrative oversight.
Effect or Potential Effect - The University was not in compliance with Cash Management requirements.
Questioned Costs – None.
Context – During our audit procedures, we noted the following:
• 1 instance of cash held in excess of the allowable time frame for the Federal Pell Grant Program for the year ended June 30, 2023
Indication of Repeat Finding - There was no similar finding identified in the prior year.
Recommendation – We recommend the University enhance its procedures to ensure that excess cash is returned timely.
Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student account billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within 2 business period, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.
Finding 2023-005 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 31 of 40 campus level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 7 of 40 campus level records tested, the University did not accurately report all campus enrollment data.
• For 23 of 40 program level records testing, the University did not accurately report all program enrollment data.
There were 29 error records during the year ended June 30, 2023 that were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2023-005, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective action for Finding 2022-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-005 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 31 of 40 campus level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 7 of 40 campus level records tested, the University did not accurately report all campus enrollment data.
• For 23 of 40 program level records testing, the University did not accurately report all program enrollment data.
There were 29 error records during the year ended June 30, 2023 that were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2023-005, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective action for Finding 2022-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution.
Finding 2023-006 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 21 of 40 Direct Loan disbursements tested, the University did not notify the borrower within the required timeframe.
Indication of Repeat Finding - There was no similar finding identified in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2023-007 – N. Special Tests and Provisions – Borrower Data and Reconciliation
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Each month, the COD provides institutions with a School Account Statement (“SAS”) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month.
Condition – The University was not able to provide supporting documentation to evidence that certain monthly SAS data file reconciliations were performed.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Borrower Data and Reconciliation requirements.
Questioned Costs – None.
Context – For 1 of 2 SAS reconciliations tested, the University was unable to provide documentation showing that the reconciliation was completed.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-002.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that SAS data files are reconciled monthly.
Views of Responsible Officials – For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this.
We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files.
During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-011 – L. Special Reporting
Information on Federal Program(s) – COVID-19 Education Stabilization Fund (84.425F)
Criteria or Specific Requirement - Quarterly Public Reporting for (a)(1) Institutional Portion funds – Institutes of Higher Education (“IHEs”) must complete and post the quarterly reporting form covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion funds and checks the “final report” box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The Year 3 report covering January 1, 2022, through December 31, 2022 was due March 24, 2023.
Condition – The annual performance report and certain quarterly reports were not completed as required.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The context for this finding is as follows:
• The University did not post reports for the quarters ended March 31, 2023 and June 30, 2023.
• The University did not submit its calendar year 2022 (Year 3) annual performance report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-007.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that HEERF data is reported in an accurate and timely manner.
Views of Responsible Officials – The University acknowledges that special reporting required for COVID-19 related, HEERF funds was not completed during fiscal year 2023. Both during and since fiscal year 2023 the business department at the University has experienced higher than usual staffing turnover. During the turnover there was a lack of train and transfer of responsibilities, which resulted in certain regulatory filings not being completed such as the HEERF reporting. Since then the business department has become fully staffed and trained. Processes and procedures relating to various government filings and reporting’s has been documented. The business department is aware of the importance of tracking any HEERF funds received or spent going forward. A schedule has been developed with any all periodic government reporting’s that must be filed. The schedule will be reviewed on an annual basis to determine if any changes are necessary.
Finding 2023-012 – A. Activities Allowed or Unallowed
Information on Federal Program(s) – COVID-19 Education Stabilization Fund (ALN 84.425F)
Criteria or Specific Requirement - The American Rescue Plan (“ARP”) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition – The University did not use any portion of its HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with required uses of grant funds.
Questioned Costs – None.
Context – As the University’s Institutional Portion grant was not used entirely for emergency financial aid grants to students, a portion of the funds must have been used to conduct direct outreach to financial aid applicants.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-009.
Recommendation – We recommend that the University enhance procedures and internal controls to ensure adherence with all federal grant terms and conditions.
Views of Responsible Officials – The University acknowledges that the COVID-19, American Rescue Plan Act funds were not spent in the correct manner. There was a lack of administrative oversight relating to the receipt and expenditure of the ARP HEERF III funds. All members of the business department have been made aware of the importance of tracking all funds especially those relating to government grants. The University has determined that any government grants over a certain threshold will be placed in a sperate bank account until it is time for them to be spent. This will eliminate the possible of the funds be misappropriated or comingled with general University funds. Any contracts related to government grants will be filed both electronically and via hard copy. The senior accountant will review any grant contracts to be aware of the purpose of the funds. Any expenditures from federal grants including HEERF will be documented and journaled on the general ledger in accordance with the department and object code expense deemed appropriate.
Finding 2023-013 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Finding 2023-014 – C. Cash Management
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs.
Condition – The University was unable to reconcile amounts drawn with amounts expended; the total amount drawn exceeded the amount expended for the fiscal year.
Certain program funds were also moved out the bank account used for federal draws and comingled with nonfederal dollars in the University’s operating bank account which resulted in a portion of the funds being used for non-program purposes. Upon identifying this issue, the University subsequent repaid the funds back, however this did not occur in a timely fashion.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cash management requirements.
Questioned Costs – None.
Context – For 4 of 6 drawdowns selected for testing, the University was unable to reconcile the amounts drawn with the amounts expended to evidence that the funds were used in a timely manner.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that documentation supporting its draws is retained and that time elapsed between transfer and disbursement of federal funds is minimized. We also recommend that the University enhances its internal controls to ensure funds are not comingled with non-program funds to prevent program funds from being used for non-program purposes.
Views of Responsible Officials – The University acknowledges that the internal controls surrounding the cash management of the Federal Research and Development Programs was not in compliance for federal standards. The University is in the process of enhancing the internal controls and cash management procedures to prevent this from happening in the future. Going forward all federal grant funds that are allocated for the Challenger Learning Center will go directly into the appropriate bank account and will be drawn down and spent in the correct time frame. When operating expenses are incurred for the Challenger Learning Center the payment will be processed from the University’s general checking and the federal grant funds will reimburse the University that day. The same is also true for the payroll expenses incurred by the Challenger Learning Center. Wages will be paid out of the university’s general checking account and then reimbursed to the university from the bank account that hold the federal grant funds.
Finding 2023-013 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Finding 2023-014 – C. Cash Management
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs.
Condition – The University was unable to reconcile amounts drawn with amounts expended; the total amount drawn exceeded the amount expended for the fiscal year.
Certain program funds were also moved out the bank account used for federal draws and comingled with nonfederal dollars in the University’s operating bank account which resulted in a portion of the funds being used for non-program purposes. Upon identifying this issue, the University subsequent repaid the funds back, however this did not occur in a timely fashion.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cash management requirements.
Questioned Costs – None.
Context – For 4 of 6 drawdowns selected for testing, the University was unable to reconcile the amounts drawn with the amounts expended to evidence that the funds were used in a timely manner.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that documentation supporting its draws is retained and that time elapsed between transfer and disbursement of federal funds is minimized. We also recommend that the University enhances its internal controls to ensure funds are not comingled with non-program funds to prevent program funds from being used for non-program purposes.
Views of Responsible Officials – The University acknowledges that the internal controls surrounding the cash management of the Federal Research and Development Programs was not in compliance for federal standards. The University is in the process of enhancing the internal controls and cash management procedures to prevent this from happening in the future. Going forward all federal grant funds that are allocated for the Challenger Learning Center will go directly into the appropriate bank account and will be drawn down and spent in the correct time frame. When operating expenses are incurred for the Challenger Learning Center the payment will be processed from the University’s general checking and the federal grant funds will reimburse the University that day. The same is also true for the payroll expenses incurred by the Challenger Learning Center. Wages will be paid out of the university’s general checking account and then reimbursed to the university from the bank account that hold the federal grant funds.
Finding 2023-015 – B. Allowable Costs/Cost Principles – Indirect costs
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009)
Criteria or Specific Requirement – NASA’s Grant and Cooperative Agreement Manual indicates that if a recipient is applying an indirect cost rate to their NASA award, the indirect cost rate must be applied on the basis of the award’s modified total direct cost (“MTDC”), which includes direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000.
Condition – The University did not accurately calculate indirect costs.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cost principles.
Questioned Costs – Below reportable threshold.
Context – The University erroneously charged indirect costs to the grant for equipment/capital expenditures.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that indirect costs are charged accordingly.
Views of Responsible Officials – The University acknowledges that the allowable indirect costs reimbursed to the University from the NASA federal grant funds was not calculated correctly for fiscal year 2023. In recent years the University has applied for a quarterly no cost extension of the previously used indirect cost rate for federal grant purposes. In March of 2024 the University actively pursued a contract with a firm known as Point Consulting to help reevaluate the currently used in direct cost rate for the University. Pont consulting has been contracted by the university in past years, but the percentage has been simply rolled forward and not adjusted. Going forward the University plans to reevaluate the indirect cost percentage in accordance with federal guidelines. The accounting department will work directly with the Challenger Learning center to make sure that indirect funds are calculated correctly and drawn down in timely and accurate manner.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-008 – N. Special Tests and Provisions – Perkins Loan Record Keeping and Record Retention
Information on Federal Program(s) - Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement - Institutions must retain original or true and exact copies of promissory and master promissory notes, repayment records, and cancellation and deferment requests for each Federal Perkins Loan Program (“Perkins”) loan made.
Condition – For certain Perkins loans, the University could not locate the original promissory notes that contained all the necessary information, including signatures.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Perkins loan recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 21 of 40 students tested, the University was unable to provide documentation evidencing proper retention of loan records.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to prevent over Perkins loan recordkeeping and record retention requirements.
Views of Responsible Officials – Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information.
The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-004 – C. Cash Management
Information on Federal Program(s) - Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement - 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 – An instance was identified where funds drawn were held in excess of the allowable time frame.
Cause - Administrative oversight.
Effect or Potential Effect - The University was not in compliance with Cash Management requirements.
Questioned Costs – None.
Context – During our audit procedures, we noted the following:
• 1 instance of cash held in excess of the allowable time frame for the Federal Pell Grant Program for the year ended June 30, 2023
Indication of Repeat Finding - There was no similar finding identified in the prior year.
Recommendation – We recommend the University enhance its procedures to ensure that excess cash is returned timely.
Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student account billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within 2 business period, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.
Finding 2023-005 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 31 of 40 campus level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 7 of 40 campus level records tested, the University did not accurately report all campus enrollment data.
• For 23 of 40 program level records testing, the University did not accurately report all program enrollment data.
There were 29 error records during the year ended June 30, 2023 that were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2023-005, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective action for Finding 2022-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-005 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 31 of 40 campus level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 7 of 40 campus level records tested, the University did not accurately report all campus enrollment data.
• For 23 of 40 program level records testing, the University did not accurately report all program enrollment data.
There were 29 error records during the year ended June 30, 2023 that were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2023-005, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective action for Finding 2022-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution.
Finding 2023-006 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 21 of 40 Direct Loan disbursements tested, the University did not notify the borrower within the required timeframe.
Indication of Repeat Finding - There was no similar finding identified in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2023-007 – N. Special Tests and Provisions – Borrower Data and Reconciliation
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Each month, the COD provides institutions with a School Account Statement (“SAS”) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month.
Condition – The University was not able to provide supporting documentation to evidence that certain monthly SAS data file reconciliations were performed.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Borrower Data and Reconciliation requirements.
Questioned Costs – None.
Context – For 1 of 2 SAS reconciliations tested, the University was unable to provide documentation showing that the reconciliation was completed.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-002.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that SAS data files are reconciled monthly.
Views of Responsible Officials – For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this.
We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files.
During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.
Finding 2023-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2022-2023 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline; however, the tuition and fees reported did not agree with the audited financial statements. The window to correct the 2022-2023 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2023-016 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based the calculated percent completed by the student.
Condition – Calculations of return of funds for a students selected for testing erroneously included scheduled breaks toward the student’s completed days, resulting in the unearned amounts to be returned to be understated.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – 1 of 2 students selected for return of Title IV funds testing.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-006.
Recommendation – We recommend that the University enhance its internal controls return of Title IV funds calculations.
Views of Responsible Officials – In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding.
The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2023-011 – L. Special Reporting
Information on Federal Program(s) – COVID-19 Education Stabilization Fund (84.425F)
Criteria or Specific Requirement - Quarterly Public Reporting for (a)(1) Institutional Portion funds – Institutes of Higher Education (“IHEs”) must complete and post the quarterly reporting form covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion funds and checks the “final report” box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The Year 3 report covering January 1, 2022, through December 31, 2022 was due March 24, 2023.
Condition – The annual performance report and certain quarterly reports were not completed as required.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The context for this finding is as follows:
• The University did not post reports for the quarters ended March 31, 2023 and June 30, 2023.
• The University did not submit its calendar year 2022 (Year 3) annual performance report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-007.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that HEERF data is reported in an accurate and timely manner.
Views of Responsible Officials – The University acknowledges that special reporting required for COVID-19 related, HEERF funds was not completed during fiscal year 2023. Both during and since fiscal year 2023 the business department at the University has experienced higher than usual staffing turnover. During the turnover there was a lack of train and transfer of responsibilities, which resulted in certain regulatory filings not being completed such as the HEERF reporting. Since then the business department has become fully staffed and trained. Processes and procedures relating to various government filings and reporting’s has been documented. The business department is aware of the importance of tracking any HEERF funds received or spent going forward. A schedule has been developed with any all periodic government reporting’s that must be filed. The schedule will be reviewed on an annual basis to determine if any changes are necessary.
Finding 2023-012 – A. Activities Allowed or Unallowed
Information on Federal Program(s) – COVID-19 Education Stabilization Fund (ALN 84.425F)
Criteria or Specific Requirement - The American Rescue Plan (“ARP”) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition – The University did not use any portion of its HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with required uses of grant funds.
Questioned Costs – None.
Context – As the University’s Institutional Portion grant was not used entirely for emergency financial aid grants to students, a portion of the funds must have been used to conduct direct outreach to financial aid applicants.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-009.
Recommendation – We recommend that the University enhance procedures and internal controls to ensure adherence with all federal grant terms and conditions.
Views of Responsible Officials – The University acknowledges that the COVID-19, American Rescue Plan Act funds were not spent in the correct manner. There was a lack of administrative oversight relating to the receipt and expenditure of the ARP HEERF III funds. All members of the business department have been made aware of the importance of tracking all funds especially those relating to government grants. The University has determined that any government grants over a certain threshold will be placed in a sperate bank account until it is time for them to be spent. This will eliminate the possible of the funds be misappropriated or comingled with general University funds. Any contracts related to government grants will be filed both electronically and via hard copy. The senior accountant will review any grant contracts to be aware of the purpose of the funds. Any expenditures from federal grants including HEERF will be documented and journaled on the general ledger in accordance with the department and object code expense deemed appropriate.
Finding 2023-013 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Finding 2023-014 – C. Cash Management
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs.
Condition – The University was unable to reconcile amounts drawn with amounts expended; the total amount drawn exceeded the amount expended for the fiscal year.
Certain program funds were also moved out the bank account used for federal draws and comingled with nonfederal dollars in the University’s operating bank account which resulted in a portion of the funds being used for non-program purposes. Upon identifying this issue, the University subsequent repaid the funds back, however this did not occur in a timely fashion.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with cash management requirements.
Questioned Costs – None.
Context – For 4 of 6 drawdowns selected for testing, the University was unable to reconcile the amounts drawn with the amounts expended to evidence that the funds were used in a timely manner.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that documentation supporting its draws is retained and that time elapsed between transfer and disbursement of federal funds is minimized. We also recommend that the University enhances its internal controls to ensure funds are not comingled with non-program funds to prevent program funds from being used for non-program purposes.
Views of Responsible Officials – The University acknowledges that the internal controls surrounding the cash management of the Federal Research and Development Programs was not in compliance for federal standards. The University is in the process of enhancing the internal controls and cash management procedures to prevent this from happening in the future. Going forward all federal grant funds that are allocated for the Challenger Learning Center will go directly into the appropriate bank account and will be drawn down and spent in the correct time frame. When operating expenses are incurred for the Challenger Learning Center the payment will be processed from the University’s general checking and the federal grant funds will reimburse the University that day. The same is also true for the payroll expenses incurred by the Challenger Learning Center. Wages will be paid out of the university’s general checking account and then reimbursed to the university from the bank account that hold the federal grant funds.