FAC Explorer

Audit 330105

FY End
2024-06-30
Total Expended
$874.22M
Findings
4
Programs
14
Organization: Liberty University, Inc. (VA)
Year: 2024 Accepted: 2024-11-27
Auditor: Bdo USA PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
512382 2024-001 Significant Deficiency Yes N
512383 2024-001 Significant Deficiency Yes N
1088824 2024-001 Significant Deficiency Yes N
1088825 2024-001 Significant Deficiency Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $744.73M Yes 1
84.063 Federal Pell Grant Program $115.58M Yes 1
84.033 Federal Work-Study Program $6.89M Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $5.73M Yes 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $590,317 Yes 0
47.041 Engineering $272,217 - 0
12.902 Information Security Grants $164,000 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $108,000 - 0
12.903 Gencyber Grants Program $44,917 - 0
93.855 Allergy and Infectious Diseases Research $37,456 - 0
93.394 Cancer Detection and Diagnosis Research $30,927 - 0
93.395 Cancer Treatment Research $15,244 - 0
84.408 Postsecondary Education Scholarships for Veteran's Dependents $13,947 Yes 0
12.560 Dod, Ndep, Dotc-Stem Education Outreach Implementation $7,901 - 0

Contacts

Name Title Type
CK9CNLPNKLK5 Scott Spear Auditee
4345924859 Jessica Doss Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported in 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. Expenditures for the federal student financial assistance program are recognized as incurred and include grants to students under the Federal Pell Grant and Federal Supplemental Educational Opportunity Grant Programs, the federal portion of student earnings under the Federal Work Study Program, and administrative cost allowances, where applicable. The Schedule includes the loan disbursements related to the University’s participation in the Federal Direct Loan Program, which are not included in the basic consolidated financial statements of the University, as these loans are made by the U.S. Department of Education. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Liberty University, Inc. (the “University”) under the programs of the federal government for the year ended June 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 US Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). All federal awards received directly and indirectly from federal agencies are included in the Schedule. All awards were in cash form. No amounts were disbursed to subrecipients. Although the University is required to match certain amounts, as defined in the grants, no such matching has been included in the Schedule. 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, changes in net assets or cash flows of the University.
Title: Basis of Accounting Accounting Policies: Expenditures reported in 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. Expenditures for the federal student financial assistance program are recognized as incurred and include grants to students under the Federal Pell Grant and Federal Supplemental Educational Opportunity Grant Programs, the federal portion of student earnings under the Federal Work Study Program, and administrative cost allowances, where applicable. The Schedule includes the loan disbursements related to the University’s participation in the Federal Direct Loan Program, which are not included in the basic consolidated financial statements of the University, as these loans are made by the U.S. Department of Education. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported in 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. Expenditures for the federal student financial assistance program are recognized as incurred and include grants to students under the Federal Pell Grant and Federal Supplemental Educational Opportunity Grant Programs, the federal portion of student earnings under the Federal Work Study Program, and administrative cost allowances, where applicable. The Schedule includes the loan disbursements related to the University’s participation in the Federal Direct Loan Program, which are not included in the basic consolidated financial statements of the University, as these loans are made by the U.S. Department of Education. The University has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Federal Direct Loan Programs Accounting Policies: Expenditures reported in 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. Expenditures for the federal student financial assistance program are recognized as incurred and include grants to students under the Federal Pell Grant and Federal Supplemental Educational Opportunity Grant Programs, the federal portion of student earnings under the Federal Work Study Program, and administrative cost allowances, where applicable. The Schedule includes the loan disbursements related to the University’s participation in the Federal Direct Loan Program, which are not included in the basic consolidated financial statements of the University, as these loans are made by the U.S. Department of Education. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. As a major source for federal student assistance, the Federal Direct Loan Program (the “Program”) provides loans to eligible borrowers to cover post-secondary education costs. The Program uses loan capital the federal government provides, requires only one aid-application (the Free Application for Federal Student Aid), and makes loans available directly through participating schools rather than through private lenders and guaranty agencies. The Program includes the Federal Subsidized Loan, the Federal Unsubsidized Loan, and the Federal PLUS Loan. The amount disbursed during the year ended June 30, 2024 under the Program was $744,730,865. The University is responsible only for the performance of certain administrative functions with respect to the Programs and, accordingly, these loans are not included in its basic consolidated financial statements. It is not practicable to determine the balance of loans outstanding to students and former students of the University under the Program at June 30, 2024.

Finding Details

Finding 2024-001
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 1 of 40 program level records tested, the University failed to report an enrollment change to NSLDS. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2024 fiscal year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely. Views of Responsible Officials: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.
Finding 2024-001
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 1 of 40 program level records tested, the University failed to report an enrollment change to NSLDS. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2024 fiscal year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely. Views of Responsible Officials: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.
Finding 2024-001
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 1 of 40 program level records tested, the University failed to report an enrollment change to NSLDS. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2024 fiscal year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely. Views of Responsible Officials: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.
Finding 2024-001
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 1 of 40 program level records tested, the University failed to report an enrollment change to NSLDS. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2024 fiscal year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely. Views of Responsible Officials: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.