Audit 329674

FY End
2024-06-30
Total Expended
$12.15M
Findings
2
Programs
11
Organization: Westminster University (UT)
Year: 2024 Accepted: 2024-11-23
Auditor: Moss Adams LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
511958 2024-001 Significant Deficiency - N
1088400 2024-001 Significant Deficiency - N

Contacts

Name Title Type
PP17KGH6HJF7 Piper Rogers Auditee
8018322139 Lisa Todd Auditor
No contacts on file

Notes to SEFA

Title: Note 1 – Basis of Presentation Accounting Policies: Note 2 – Summary of Significant Accounting Policies-Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Westminster University and affiliate (the University) for the year ended June 30, 2024. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to, and does not, present the consolidated financial position, changes in net assets, functional expenses, or cash flows of the University.
Title: Note 2 – Summary of Significant Accounting Policies Accounting Policies: Note 2 – Summary of Significant Accounting Policies-Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance.
Title: Note 3 – Federal Student Loan Programs Accounting Policies: Note 2 – Summary of Significant Accounting Policies-Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. During the year ended June 30, 2024, the University issued new loans to students under the Federal Direct Loan Program (FDLP). The value of loans issued for the FDLP is based on disbursed amounts. The University is responsible only for the performance of certain administrative duties with respect to the federally guaranteed student loan programs and, accordingly, balances and transactions relating to these loan programs are not included in the University’s consolidated financial statements. Therefore, it is not the responsibility of the University to determine the balance of loans outstanding to students and former students of the University at June 30, 2024. The loans made by the University to eligible students under the FDLP during the year ended June 30, 2024, are summarized as follows: See the notes to the SEFA for table. The Federal Perkins Loan Program is administered directly by the University, and balances and transactions relating to these programs are included in the University’s consolidated financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. There were no new loans made under the Federal Perkins Loan Program for the year ended June 30, 2024. The balance of loans outstanding at June 30, 2024, consists of: See the notes to the SEFA for table.

Finding Details

FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.268 Federal Program Name: Student Financial Assistance Cluster Award Year: 2023-24 Criteria: Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition and Context: A sample of 46 students who had address changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 935 total address changes. We noted that the process for reporting address changes did not take place regularly during the year. We noted that of 46 students sampled and tested, eight students did not have their address changes reported to NSLDS. Upon further investigation, we determined that internal controls were not in place and operating effectively to timely report address changes during the year. We did not expand our sample. Questioned Costs: None Effect: The University did not regularly report address changes to the National Student Loan Data System (NSLDS). As such, the address changes were not reported timely. This information is utilized by the U.S. Department of Education, the Federal Direct Loan program, lenders, and other institutions. Cause: This occurred because the process in place was not designed effectively to timely report address changes to NSLDS. Repeat Finding: No Recommendation: We recommend the University implement a process to ensure address changes for all terms are timely reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions: Upon review of our process, we noted that the data we provided was not limited to Home/Permanent address changes. As a result, the selections did not demonstrate our timely reporting. Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated.
FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.268 Federal Program Name: Student Financial Assistance Cluster Award Year: 2023-24 Criteria: Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition and Context: A sample of 46 students who had address changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 935 total address changes. We noted that the process for reporting address changes did not take place regularly during the year. We noted that of 46 students sampled and tested, eight students did not have their address changes reported to NSLDS. Upon further investigation, we determined that internal controls were not in place and operating effectively to timely report address changes during the year. We did not expand our sample. Questioned Costs: None Effect: The University did not regularly report address changes to the National Student Loan Data System (NSLDS). As such, the address changes were not reported timely. This information is utilized by the U.S. Department of Education, the Federal Direct Loan program, lenders, and other institutions. Cause: This occurred because the process in place was not designed effectively to timely report address changes to NSLDS. Repeat Finding: No Recommendation: We recommend the University implement a process to ensure address changes for all terms are timely reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions: Upon review of our process, we noted that the data we provided was not limited to Home/Permanent address changes. As a result, the selections did not demonstrate our timely reporting. Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated.