Audit 326552

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-002: Federal Program: U.S. Department of Education Federal Direct Loan Program, CFDA 84.268 Criteria: The University must comply with 34 CFR Section 685.309(b). Condition: During our testing of 40 official withdrawals, we noted two students for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change due to external credits for professional study courses erroneously being included within the students' total credit hours and thus improperly classifying them on the University's roster files. Additional analysis performed by the University on the remaining population of students with external credits identified an additional 12 students for which the NSLDS was not notified timely of the correct student status change. During our testing of three unofficial withdrawals, we noted one Spring semester student for which the NSLDS was not notified timely of the student status change. Additional analysis of all unofficial withdrawals for Spring 2024 resulted in 10 additional students for which the NSLDS was not notified timely of the correct student status change. Cause: The University did not have controls in place to ensure students' classification based upon actual allowable credit hours were being properly reported to the NSLDS. Unofficial withdrawals were also not being monitored to ensure timely reporting to the NSLDS. Effect: The provisions of 34 CFR Section 685.309(b) were not followed and thus a total of 27 students had untimely and incorrect status changes reported to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement controls to ensure roster files are updated correctly and reviewed before reported to the NSLDS. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with IT to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days.

Finding 2024-003, (Repeat of 2023-002): Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Federal Award Identification No. 20T26H39452, Award Year 2020 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.

Finding 2024-003, (Repeat of 2023-002): Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Federal Award Identification No. 20T26H39452, Award Year 2020 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.

Finding 2024-004: Federal Program: U.S. Department of Education Student Financial Aid Cluster: Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Criteria: The University must comply with 34 CFR 685.301. Condition: During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.

Finding 2024-004: Federal Program: U.S. Department of Education Student Financial Aid Cluster: Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Criteria: The University must comply with 34 CFR 685.301. Condition: During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.

Finding 2024-002: Federal Program: U.S. Department of Education Federal Direct Loan Program, CFDA 84.268 Criteria: The University must comply with 34 CFR Section 685.309(b). Condition: During our testing of 40 official withdrawals, we noted two students for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change due to external credits for professional study courses erroneously being included within the students' total credit hours and thus improperly classifying them on the University's roster files. Additional analysis performed by the University on the remaining population of students with external credits identified an additional 12 students for which the NSLDS was not notified timely of the correct student status change. During our testing of three unofficial withdrawals, we noted one Spring semester student for which the NSLDS was not notified timely of the student status change. Additional analysis of all unofficial withdrawals for Spring 2024 resulted in 10 additional students for which the NSLDS was not notified timely of the correct student status change. Cause: The University did not have controls in place to ensure students' classification based upon actual allowable credit hours were being properly reported to the NSLDS. Unofficial withdrawals were also not being monitored to ensure timely reporting to the NSLDS. Effect: The provisions of 34 CFR Section 685.309(b) were not followed and thus a total of 27 students had untimely and incorrect status changes reported to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement controls to ensure roster files are updated correctly and reviewed before reported to the NSLDS. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with IT to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days.

Finding 2024-003, (Repeat of 2023-002): Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Federal Award Identification No. 20T26H39452, Award Year 2020 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.

Finding 2024-003, (Repeat of 2023-002): Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Federal Award Identification No. 20T26H39452, Award Year 2020 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.

Finding 2024-004: Federal Program: U.S. Department of Education Student Financial Aid Cluster: Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Criteria: The University must comply with 34 CFR 685.301. Condition: During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.

Finding 2024-004: Federal Program: U.S. Department of Education Student Financial Aid Cluster: Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Criteria: The University must comply with 34 CFR 685.301. Condition: During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.