FAC Explorer

Audit 329791

FY End
2024-05-31
Total Expended
$49.58M
Findings
14
Programs
18
Organization: Bradley University (IN)
Year: 2024 Accepted: 2024-11-25
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
512056 2024-001 Significant Deficiency - L
512057 2024-002 Significant Deficiency Yes L
512058 2024-002 Significant Deficiency Yes L
512059 2024-003 Significant Deficiency - L
512060 2024-003 Significant Deficiency - L
512061 2024-003 Significant Deficiency - L
512062 2024-003 Significant Deficiency - L
1088498 2024-001 Significant Deficiency - L
1088499 2024-002 Significant Deficiency Yes L
1088500 2024-002 Significant Deficiency Yes L
1088501 2024-003 Significant Deficiency - L
1088502 2024-003 Significant Deficiency - L
1088503 2024-003 Significant Deficiency - L
1088504 2024-003 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $37.51M Yes 3
84.063 Federal Pell Grant Program $6.63M Yes 2
84.038 Perkins Loan Program $1.94M Yes 0
11.307 Economic Adjustment Assistance $978,114 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $645,830 Yes 1
11.611 Manufacturing Extension Partnership $494,895 - 0
84.033 Federal Work-Study Program $375,851 Yes 1
12.800 Air Force Defense Research Sciences Program $351,877 - 0
93.364 Nursing Student Loans $203,430 Yes 0
47.076 Stem Education (formerly Education and Human Resources) $200,117 - 0
84.153 Business and International Education Projects $40,910 - 0
81.049 Office of Science Financial Assistance Program $32,902 - 0
20.205 Highway Planning and Construction $29,631 - 0
93.052 National Family Caregiver Support, Title Iii, Part E $23,241 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $3,945 - 0
93.351 Research Infrastructure Programs $3,922 - 0
43.008 Office of Stem Engagement (ostem) $2,692 - 0
47.070 Computer and Information Science and Engineering $2,509 - 0

Contacts

Name Title Type
D3ZVNXBL1DJ7 Betsy Hull Auditee
3096767611 Jared Clark Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures for federal student finiacial aid programs are recognized as incurred and include Pell program grants to students, the federal share of the student's Federal Supplemental Educational Opportunity Grant (FSEOG) program, and Federal Work Study (FWS) program. Expenditures for federal programs are recognized as incurred using 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. Moreover, expenditures include a portion of costs associated with general University activities (indirect costs) which are allocated to federal awards under negotiated formulas commonly referred to as indirect cost rates. The University has not elected to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Indirect costs allocated to such awards for the year ended May 31, 2024 were based on predetermined fixed rates as stipulated in the respective grant agreements or as negotiated with the Department of Health and Human Services. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) summarizes the expenditures of Bradley University (the University) under programs of the federal government for the fiscal year ended May 31, 2024. The information in this Schedule is presented in accordance with the requirements of 2 CFR 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 financial position, or the changes in net assets and cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all sub awards to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures for federal student finiacial aid programs are recognized as incurred and include Pell program grants to students, the federal share of the student's Federal Supplemental Educational Opportunity Grant (FSEOG) program, and Federal Work Study (FWS) program. Expenditures for federal programs are recognized as incurred using 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. Moreover, expenditures include a portion of costs associated with general University activities (indirect costs) which are allocated to federal awards under negotiated formulas commonly referred to as indirect cost rates. The University has not elected to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Indirect costs allocated to such awards for the year ended May 31, 2024 were based on predetermined fixed rates as stipulated in the respective grant agreements or as negotiated with the Department of Health and Human Services. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of the student’s Federal Supplemental Educational Opportunity Grant (FSEOG) program, and Federal Work Study (FWS) program. Expenditures for federal programs are recognized as incurred using 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. Moreover, expenditures include a portion of costs associated with general University activities (indirect costs) which are allocated to federal awards under negotiated formulas commonly referred to as indirect cost rates. The University has not elected to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Indirect costs allocated to such awards for the year ended May 31, 2024 were based on predetermined fixed rates as stipulated in the respective grant agreements or as negotiated with the Department of Health and Human Services.
Title: Federal Student Loans Programs Accounting Policies: Expenditures for federal student finiacial aid programs are recognized as incurred and include Pell program grants to students, the federal share of the student's Federal Supplemental Educational Opportunity Grant (FSEOG) program, and Federal Work Study (FWS) program. Expenditures for federal programs are recognized as incurred using 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. Moreover, expenditures include a portion of costs associated with general University activities (indirect costs) which are allocated to federal awards under negotiated formulas commonly referred to as indirect cost rates. The University has not elected to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Indirect costs allocated to such awards for the year ended May 31, 2024 were based on predetermined fixed rates as stipulated in the respective grant agreements or as negotiated with the Department of Health and Human Services. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The federal student loan programs listed subsequently are administered directly by the University, and balances and transactions relating to these programs are included in University's basic finiancial 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. The balance of loans outstanding at May 31, 2024 consists of: Federal Perkins Loan Program: Amount outstanding: $1,330,693. Nursing Student Loans: $152,590. As of and during the year ended May 31, 2024, the University did not receive any noncash federal assistance or federal insurance.
Title: Additional Information Accounting Policies: Expenditures for federal student finiacial aid programs are recognized as incurred and include Pell program grants to students, the federal share of the student's Federal Supplemental Educational Opportunity Grant (FSEOG) program, and Federal Work Study (FWS) program. Expenditures for federal programs are recognized as incurred using 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. Moreover, expenditures include a portion of costs associated with general University activities (indirect costs) which are allocated to federal awards under negotiated formulas commonly referred to as indirect cost rates. The University has not elected to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Indirect costs allocated to such awards for the year ended May 31, 2024 were based on predetermined fixed rates as stipulated in the respective grant agreements or as negotiated with the Department of Health and Human Services. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. As of and during the year ended May 31, 2024, the University did not receive any noncash federal assistance or federal insurance.

Finding Details

Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Condition: One student refund resulting from the Parent Plus loan was not refunded for 16 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required compliance requirements were met. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Repeat finding: No Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Condition: One student refund resulting from the Parent Plus loan was not refunded for 16 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required compliance requirements were met. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Repeat finding: No Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.