2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 004
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year.
Award Period: July 1, 2023, through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding: Yes – 2023-005.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 004
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year.
Award Period: July 1, 2023, through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding: Yes – 2023-005.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 001
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition:
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period.
Questioned Costs:
N/A
Context:
During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period.
Cause:
The University did not properly review Credit Balance required procedures.
Effect:
The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations.
Repeat Finding:
No.
Recommendation:
We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 002
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through 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 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition:
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024.
Questioned Costs:
$494.20
Context:
The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies.
Cause:
The University did not properly review SFA Outstanding Student Title IV Check required procedures.
Effect:
The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Recommendation:
We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers:
84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements.
Condition:
The University had not updated changes in top management positions within the allotted 10-day timeframe.
Questioned Costs:
N/A
Context:
The University did not have an official process is in place to ensure top management positions were updated timely.
Cause:
The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion.
Effect:
The University is not in compliance with Department of Education requirements.
Recommendation:
We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 004
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year.
Award Period: July 1, 2023, through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding: Yes – 2023-005.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.
2024 – 004
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year.
Award Period: July 1, 2023, through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding: Yes – 2023-005.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.