FAC Explorer

Audit 333674

FY End
2024-05-31
Total Expended
$42.40M
Findings
2
Programs
15
Organization: Ashland University (OH)
Year: 2024 Accepted: 2024-12-19
Auditor: Schneider Downs

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
515819 2024-001 Significant Deficiency Yes N
1092261 2024-001 Significant Deficiency Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $20.10M Yes 0
84.063 Federal Pell Grant Program $18.93M Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $905,415 Yes 0
93.264 Nurse Faculty Loan Program (nflp) $816,296 Yes 0
84.038 Federal Perkins Loan (fpl) - Federal Capital Contributions $455,170 Yes 0
84.033 Federal Work-Study Program $402,804 Yes 0
84.425 Elementary and Secondary School Emergency Relief Fund $345,460 - 0
84.116 Fund for the Improvement of Postsecondary Education $139,910 - 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $98,544 Yes 0
93.867 Vision Research $77,898 - 0
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $21,035 - 0
10.216 1890 Institution Capacity Building Grants $18,804 - 0
81.049 Office of Science Financial Assistance Program $15,217 - 0
59.037 Small Business Development Centers $2,591 - 0
47.074 Biological Sciences $646 - 0

Contacts

Name Title Type
X6L3Z7TS3RE3 Janet Edwards Auditee
4192075574 Patrick Kerns Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 - BASIS OF ACCOUNTING Accounting Policies: The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) De Minimis Rate Used: N Rate Explanation: See NOTE 3 This Schedule of Expenditures of Federal Awards (Schedule) includes the federal awards activity of Ashland University (University) and is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance); therefore, some amounts presented in this Schedule may differ from amounts presented in or used in the preparation of the basic financial statements. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows. Assistance Listing numbers are presented for those programs for which such numbers were available. All programs are presented by federal agency. Pass-through programs are also presented by the entity through which the University received the federal award.
Title: NOTE 2 - LOANS Accounting Policies: The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) De Minimis Rate Used: N Rate Explanation: See NOTE 3 Federal Direct Loan Program The University participates in the Federal Direct Student Loan Program (84.268). The University originates but does not provide funding for the Federal Direct Student Loan Program (FDSL). The $20,099,201 presented on the Schedule of Expenditures of Federal Awards represents the value of new FDSL processed by the University for the year ended May 31, 2024. Federal Perkins Loan Program The amount presented on the Schedule for the Federal Perkins Loan Program (84.038) represents loans outstanding at the beginning of the year for which the government imposes continuing compliance requirements. The balance of Federal Perkins Loans outstanding as of May 31, 2024 was $242,313. Nurse Faculty Loan Program The amount presented on the Schedule for the Nurse Faculty Loan Program (93.264) represents loans outstanding at the beginning of the year for which the government imposes continuing compliance requirements. The balance of Nurse Faculty Loans outstanding as of May 31, 2024 was $967,927.
Title: NOTE 3 - INDIRECT COST RATE Accounting Policies: The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) De Minimis Rate Used: N Rate Explanation: See NOTE 3 The University has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.
Title: NOTE 4 - COMMITMENT AND CONTINGENT LIABILITIES Accounting Policies: The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) De Minimis Rate Used: N Rate Explanation: See NOTE 3 The ED informed the University in August 2021 that it would be performing a focused program review in September 2021 concerning the University’s participation in the ESI, Pell grant and FWS programs. On September 16, 2022, the University received ED’s Final Program Review Determination (FPRD). The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act § 487(b)(2) and U.S.C. § 1094(b)(2) on January 23, 2023, dated January 21, 2023. On March 6, 2023, the U.S. Department of Education Office of Federal Student Aid submitted its brief in support of its position to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act § 487(b)(2) and U.S.C. § 1094(b)(2). The appeal process stays ED’s ability to collect the financial assessments, but interest will continue to accrue on the amounts determined in the FPRD from the date of the appeal until either the matter is settled or all legal means are exhausted. On May 11, 2023, the Chief Administrative Law Judge (Judge) held a hearing and the parties presented oral arguments. The Judge’s initial decision was provided to the parties on July 10, 2023, which upholds the findings and liabilities in the FPRD. The ED Office of Hearings and Appeals Judge issued its final decision on September 20, 2023, and preserves the findings and liabilities in the FPRD. The University has elected not to appeal to the Secretary of the U.S. Department of Education as available per 34 CFR 668.119 (a) and the University has appealed to the United States District Court for the Northern District of Ohio Eastern District at Cleveland (District Court) by a court filing on September 23, 2023. The University has recorded a $7,300,000 liability of an estimated amount as of and for the year ended May 31, 2024, as a result of the pending final decision from the Judge and in accordance with FASB Codification Topic 450-20 - Loss Contingencies. On May 16, 2024, the University received a final audit determination (FAD) notice from ED regarding the May 31, 2022 audit findings and the associated liability of $2,300,000 and ED’s intention to either seek collection of the amount or permit the University the ability to appeal this final audit determination. The University filed pursuant to 34 C.F.R. § 668.113(a), a Request for Review of the FAD with the U.S. Department of Education Administrative Actions and Appeals Services Group (AAASG). The AAASG transmitted this matter for a review and hearing to the OHA. On August 29, 2024, Ashland University and the Office of General Counsel U. S. Department of Education filed a Joint Motion to Hold Proceeding in Abeyance. As a result of the legal issues in the litigation in District Court, which are identical to the issues in this matter, ED has agreed to hold this matter in abeyance and not pursue any efforts to collect the balance related to the May 31, 2022 audit pending resolution to the litigation that was filed. These amounts were not recorded in the accompanying Schedule as they do not impact any amounts expended in relation to the aforementioned programs during the year ended May 31, 2024. These amounts might not need to be returned to ED; however, the determination of any amount that needs to be returned to ED depends on the resolution of the appeal to the District Court, which could require a significant period of time. As of the issuance date of the University’s Schedule for the year ended May 31, 2024, there was no ruling or judgement rendered relative to the University’s filing in District Court.

Finding Details

Finding 2024-001
Identification of the federal program and specific federal award: i. Assistance listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (ED) (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. § 685.309(b). c. Condition: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding its participation in the “Pell for Students Who Are Incarcerated” experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years, and update and correct errors identified. Cause: ED, as a result of the FPR and the findings contained within the Final Program Review Determination (FPRD) on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University’s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED’s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to the issuance of the FPRD and completed this process subsequent to May 31, 2023. h. Identification as a repeat finding, if applicable: This is a repeat finding of Finding 2023-001. i. Recommendation: We recommend the University review its policies and procedures to ensure that there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar’s Office has performed a further review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS. A how-to manual has been developed and training has occurred and regular training cadence has been developed utilizing training resources provided by associations and the U.S. Department of Education. The required corrections were completed on September 30, 2024.
Finding 2024-001
Identification of the federal program and specific federal award: i. Assistance listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (ED) (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. § 685.309(b). c. Condition: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding its participation in the “Pell for Students Who Are Incarcerated” experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years, and update and correct errors identified. Cause: ED, as a result of the FPR and the findings contained within the Final Program Review Determination (FPRD) on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University’s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED’s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to the issuance of the FPRD and completed this process subsequent to May 31, 2023. h. Identification as a repeat finding, if applicable: This is a repeat finding of Finding 2023-001. i. Recommendation: We recommend the University review its policies and procedures to ensure that there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar’s Office has performed a further review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS. A how-to manual has been developed and training has occurred and regular training cadence has been developed utilizing training resources provided by associations and the U.S. Department of Education. The required corrections were completed on September 30, 2024.