Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063; 84.268 Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: ? 1 student out of sample of 5 students tested was reported to NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 2 students out of sample of 5 students tested were not reported to the campus-level record in the NSLDS within a timely manner. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly or not timely communicates information to the NSLDS, which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001.
Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063; 84.268 Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: ? 1 student out of sample of 5 students tested was reported to NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 2 students out of sample of 5 students tested were not reported to the campus-level record in the NSLDS within a timely manner. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly or not timely communicates information to the NSLDS, which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F200150 - 2022 Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Questioned costs: None. Context: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment which could cause the University to be in noncompliance with certain federal awards they receive. Effect: The University could potentially be in noncompliance with certain regulations. Repeat Finding: No. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to limit the risk for noncompliance. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063; 84.268 Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: ? 1 student out of sample of 5 students tested was reported to NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 2 students out of sample of 5 students tested were not reported to the campus-level record in the NSLDS within a timely manner. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly or not timely communicates information to the NSLDS, which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001.
Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063; 84.268 Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: ? 1 student out of sample of 5 students tested was reported to NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 2 students out of sample of 5 students tested were not reported to the campus-level record in the NSLDS within a timely manner. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly or not timely communicates information to the NSLDS, which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F200150 - 2022 Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Questioned costs: None. Context: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment which could cause the University to be in noncompliance with certain federal awards they receive. Effect: The University could potentially be in noncompliance with certain regulations. Repeat Finding: No. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to limit the risk for noncompliance. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.