Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest expected family contributions who will not receive Federal Pell Grants.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University awarded FSEOG to students with EFC’s higher than zero (the lowest expected family contribution) when there were students with the zero EFCs who did not receive FSEOG and were eligible to receive FSEOG. Questioned costs: $800. Context: In our sample of 13 FSEOG recipients two were identified that had an EFC higher than zero. Both were within the University's policy to award eligible students with EFCs in the 0-3500 range who meet the priority deadline. In our eligibility sample of 40, we identified 2 Pell recipients with a zero EFC and remaining need that were not awarded FSEOG funds. Cause: The University's policy is to award FSEOG to PELL recipients who have met the FAFSA priority deadline and have an EFC below 3,500. The University policy for awarding FSEOG funds was not capturing all students who had the lowest EFC and remaining need. Effect: The University is not in compliance with the FSEOG awarding guidelines. Repeat finding: Yes, 2023-004. Recommendation: We recommend that the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; Federal Award Identification Number and Year: P268K240101 – 2024; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of loan disbursements, we identified instances in which students did not receive notification of their loan disbursement. Questioned costs: None. Context: In our testing of loan disbursements, we identified 23 out of 40 students tested did not receive notification of their loan disbursement. Students were only notified if there was a change to their loan award and were not notified of loan disbursements. Cause: The University did not have proper procedures in place to ensure all students were notified of their loan disbursements. Effect: The University was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. Repeat finding: No. Recommendation: We recommend the University evaluate the procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Agriculture; Federal Program Name: Partnerships for Climate-Smart Commodities; Assistance Listing Number: 10.937; Federal Award Identification Number and Year: 2023-2024 – NR233A750004G038; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance. Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have observable controls to test over the Federal Funding. Accountability and Transparency Act (FFATA) reporting process. Questioned costs: None. Context: During our testing of the 3 FFATA reports submitted by the University during the year ended June 30, 2024, we noted there was no documentation of the University’s review process of the FFATA reports. Cause: The procedures the University had over the review of the FFATA reports did not include documentation of the control over reporting. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat finding: No. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Views of responsible officials and planned corrective action: Management agrees they were not able to provide evidence of the review of the FFATA report.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest expected family contributions who will not receive Federal Pell Grants.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University awarded FSEOG to students with EFC’s higher than zero (the lowest expected family contribution) when there were students with the zero EFCs who did not receive FSEOG and were eligible to receive FSEOG. Questioned costs: $800. Context: In our sample of 13 FSEOG recipients two were identified that had an EFC higher than zero. Both were within the University's policy to award eligible students with EFCs in the 0-3500 range who meet the priority deadline. In our eligibility sample of 40, we identified 2 Pell recipients with a zero EFC and remaining need that were not awarded FSEOG funds. Cause: The University's policy is to award FSEOG to PELL recipients who have met the FAFSA priority deadline and have an EFC below 3,500. The University policy for awarding FSEOG funds was not capturing all students who had the lowest EFC and remaining need. Effect: The University is not in compliance with the FSEOG awarding guidelines. Repeat finding: Yes, 2023-004. Recommendation: We recommend that the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.
Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; Federal Award Identification Number and Year: P268K240101 – 2024; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of loan disbursements, we identified instances in which students did not receive notification of their loan disbursement. Questioned costs: None. Context: In our testing of loan disbursements, we identified 23 out of 40 students tested did not receive notification of their loan disbursement. Students were only notified if there was a change to their loan award and were not notified of loan disbursements. Cause: The University did not have proper procedures in place to ensure all students were notified of their loan disbursements. Effect: The University was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. Repeat finding: No. Recommendation: We recommend the University evaluate the procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Agriculture; Federal Program Name: Partnerships for Climate-Smart Commodities; Assistance Listing Number: 10.937; Federal Award Identification Number and Year: 2023-2024 – NR233A750004G038; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance. Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have observable controls to test over the Federal Funding. Accountability and Transparency Act (FFATA) reporting process. Questioned costs: None. Context: During our testing of the 3 FFATA reports submitted by the University during the year ended June 30, 2024, we noted there was no documentation of the University’s review process of the FFATA reports. Cause: The procedures the University had over the review of the FFATA reports did not include documentation of the control over reporting. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat finding: No. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Views of responsible officials and planned corrective action: Management agrees they were not able to provide evidence of the review of the FFATA report.