Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Higher Education Institutional Aid
Assistance Listing Number 84.031S
Federal Award Identification Number and Year P031S200249 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency.
Compliance Not Material
Document judgment for your assessment See line 28 for more detailed response
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known 12,965.60
Likely 333907.5
Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The University could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Higher Education Institutional Aid
Assistance Listing Number 84.031S
Federal Award Identification Number and Year P031S200249 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Allowable Costs
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance N/A - I/C Finding Only
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition The University did not review scholarship awards made with federal program funds.
Questioned costs: N/A
Known
Likely
Context During our testing of 8 scholarship transactions, we observed 8 instances where scholarship awards did not have evidence of review prior to the award of funds to students.
Cause The University did adhere to existing controls in place to review the federal program scholarship awards.
Effect Scholarships may be awarded that are disallowed from program funds and may go undetected for substantial periods of time.
Repeat Finding No
Recommendation We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Higher Education Institutional Aid
Assistance Listing Number 84.031S
Federal Award Identification Number and Year P031S200249 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency.
Compliance Not Material
Document judgment for your assessment See line 28 for more detailed response
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known 12,965.60
Likely 333907.5
Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The University could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Higher Education Institutional Aid
Assistance Listing Number 84.031S
Federal Award Identification Number and Year P031S200249 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Allowable Costs
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance N/A - I/C Finding Only
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition The University did not review scholarship awards made with federal program funds.
Questioned costs: N/A
Known
Likely
Context During our testing of 8 scholarship transactions, we observed 8 instances where scholarship awards did not have evidence of review prior to the award of funds to students.
Cause The University did adhere to existing controls in place to review the federal program scholarship awards.
Effect Scholarships may be awarded that are disallowed from program funds and may go undetected for substantial periods of time.
Repeat Finding No
Recommendation We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan.
Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem.
Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds
Repeat Finding No
Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Material Weakness
Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms.
Compliance Material
Document judgment for your assessment Appears to be systemic.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
Questioned costs:
Known $5,095.00
Likely See Questioned Cost Tab
Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds.
Additionally, one R2T4 calculation did not have documentation of review."
Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed.
Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
Repeat Finding Yes
Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade.
"
Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner.
Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding Yes
Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of Responsible Officials Agree