2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 006Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.063Federal Award Identification Number and Year: P063P212135, P063P222135; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.Condition:Pell Grant disbursements to the students were not properly reported to the COD system by Kutztown University within the 15-day timeframe.Questioned Costs:NoneContext:During our testing at Kutztown University, we noted 1 of the 25 Pell disbursements tested were not reported to the Common Origination and Disbursement (COD) system within the required 15 days.Cause:The University?s policies and procedures did not ensure that aid disbursement information was timely reported to COD.Effect:Students? interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.Repeat Finding:NoRecommendation:We recommend the University should review its policies and procedures around COD reporting to ensure students? information is reporting timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 002Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month.Condition:Kutztown and Cheyney Universities did not certify status changes timely and Cheyney University also did not certify student information timely.Questioned Costs:N/AContext:During our testing of NSLDS Enrollment Reporting, we noted:1) Status change was received by NSLDS was outside of the 60 day timeframe:? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 12 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 15 of the 15 students tested for award year 2021-222) Student was not being certified every 60 days:? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 9 of the 15 students tested for award year 2021-22Cause:The Universities? policies and procedures did not ensure that student status changes were timely reported to NSLDS.Effect:The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.Repeat Finding:Cheyney University ? Yes ? Finding 2021-003Kutztown University ? NoRecommendation:The Universities should review their reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 005Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.268Federal Award Identification Number and Year: P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who ceases at least half-time study at the school.Condition:California University did not provide exit counseling timely for all students ceasing attendance during the year.Questioned Costs:NoneContext:Four of the 25 students selected for eligibility testing at California University did not perform exit counseling within the required 30 days of the student ceasing attendance.Cause:The University?s processes and controls did not ensure that entrance or exit counseling was completed or did not retain proper support to indicate this process took place.Effect:Students are not receiving the proper loan counseling which may contribute to a higher default rate.Repeat Finding:NoRecommendation:We recommend the University review its policies and procedures around sending entrance and exit counseling information to students to ensure students are receiving proper counseling and ensure exit counseling is performed and documented within the required timeframe.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 007Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.268Federal Award Identification Number and Year: P268K212136 and P268K222136; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021, through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.300(b)(5), requires the University monthly to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.Condition:Lock Haven University did not properly perform and review monthly Direct Loan reconciliations throughout the award year.Questioned Costs:NoneContext:During the prior year finding follow-up performed, the University could not produce documentation that Direct Loan Reconciliations were reviewed.Cause:The University management did not have the appropriate coordination or communication with the financial aid team to review the reconciliations and maintain the appropriate documentation.Effect:The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled.Repeat Finding:Yes ? Finding 2021-002Recommendation:The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 006Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.063Federal Award Identification Number and Year: P063P212135, P063P222135; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.Condition:Pell Grant disbursements to the students were not properly reported to the COD system by Kutztown University within the 15-day timeframe.Questioned Costs:NoneContext:During our testing at Kutztown University, we noted 1 of the 25 Pell disbursements tested were not reported to the Common Origination and Disbursement (COD) system within the required 15 days.Cause:The University?s policies and procedures did not ensure that aid disbursement information was timely reported to COD.Effect:Students? interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.Repeat Finding:NoRecommendation:We recommend the University should review its policies and procedures around COD reporting to ensure students? information is reporting timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 002Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month.Condition:Kutztown and Cheyney Universities did not certify status changes timely and Cheyney University also did not certify student information timely.Questioned Costs:N/AContext:During our testing of NSLDS Enrollment Reporting, we noted:1) Status change was received by NSLDS was outside of the 60 day timeframe:? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 12 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 15 of the 15 students tested for award year 2021-222) Student was not being certified every 60 days:? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 9 of the 15 students tested for award year 2021-22Cause:The Universities? policies and procedures did not ensure that student status changes were timely reported to NSLDS.Effect:The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.Repeat Finding:Cheyney University ? Yes ? Finding 2021-003Kutztown University ? NoRecommendation:The Universities should review their reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 003Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.063 and 84.268Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.309(b), states that:1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not.2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS.Condition:California University had errors in the Enrollment Effective Dates, Program Enrollment Effective Dates, Enrollment Statuses, and Program Enrollment Statuses reported to NSLDS. Kutztown University also had errors in both the Enrollment Effective Dates and Program Enrollment Statuses reported while Cheyney University only had errors in the Enrollment Effective Dates reported.Questioned Costs:N/AContext:During our testing of enrollment status reporting on the State System, we noted:1) Incorrect Enrollment Effective Date Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 3 of the 40 students tested for award year 2021-22? Cheyney University (P063P212131, P063P222131, P268K212131, and P268K222131): 1 of the 15 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 1 of the 40 students tested for award year 2021-22? Slippery Rock University (P063P202140, P063P212140, P268K212140, P268K222140): 1 of the 40 students tested for award year 2021-222) Incorrect Program Enrollment Effective Date Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 2 of the 40 students tested for award year 2021-223) Incorrect Enrollment Status Reported to NSLDS? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 4 of the 40 students tested for award year 2021-224) Incorrect Program Enrollment Status Reported to NSLDS? Kutztown University (P063P212135, P063P222135, P268K212135, and P268K222135): 5 of the 40 students tested for award year 2021-22? California University (P063P212130, P063P222130, P268K212130, and P268K222130): 3 of the 40 students tested for award year 2021-22Causes:1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student?s last date of attendance.2) California University did not have a process in place to ensure the student's program enrollment effective date was being accurately reported.3) California University did not have a process in place to ensure the student's enrollment status was being accurately reported.4) California and Kutztown Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported.Effect:1) The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.2) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.Repeat Finding:Cheyney University ? Yes ? Finding 2021-004All Other Universities ? NoRecommendation:1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.2) The University should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS.3) The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.4) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 004Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Numbers: 84.007, 84.033, 84.063, 84.268Federal Award Identification Number and Year: P007A213550, P007A223550, P033A213550, P033A223550, P063P212130, P063P222130, P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.Condition:California University incorrectly calculated the number of scheduled break days included in the Return to Title IV (R2T4) aid calculations performed.Questioned Costs:Not determined.Context:During our testing at California University, we noted 10 of the 40 students tested for award year 2021-22 included an incorrect amount of scheduled break days within the R2T4 aid calculation.Cause:California University did not update their R2T4 calculation to include spring break days after the COVID pandemic. Adding back spring break days was overlooked after spring break resumed.Effect:The University is not completing accurate R2T4 calculations as defined by the regulations.Repeat Finding:NoRecommendation:We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 005Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.268Federal Award Identification Number and Year: P268K212130, and P268K222130; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who ceases at least half-time study at the school.Condition:California University did not provide exit counseling timely for all students ceasing attendance during the year.Questioned Costs:NoneContext:Four of the 25 students selected for eligibility testing at California University did not perform exit counseling within the required 30 days of the student ceasing attendance.Cause:The University?s processes and controls did not ensure that entrance or exit counseling was completed or did not retain proper support to indicate this process took place.Effect:Students are not receiving the proper loan counseling which may contribute to a higher default rate.Repeat Finding:NoRecommendation:We recommend the University review its policies and procedures around sending entrance and exit counseling information to students to ensure students are receiving proper counseling and ensure exit counseling is performed and documented within the required timeframe.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 007Federal Agency: Department of EducationFederal Program Name: Student Financial Assistance ClusterAssistance Listing Number: 84.268Federal Award Identification Number and Year: P268K212136 and P268K222136; all grants were awarded within the 2020-21 and 2021-22 award yearsAward Period: July 1, 2021, through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 34 CFR 685.300(b)(5), requires the University monthly to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.Condition:Lock Haven University did not properly perform and review monthly Direct Loan reconciliations throughout the award year.Questioned Costs:NoneContext:During the prior year finding follow-up performed, the University could not produce documentation that Direct Loan Reconciliations were reviewed.Cause:The University management did not have the appropriate coordination or communication with the financial aid team to review the reconciliations and maintain the appropriate documentation.Effect:The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled.Repeat Finding:Yes ? Finding 2021-002Recommendation:The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.