Finding 2024-011 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 7 of 8 employees tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-013.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document time and effort associated with research and development cluster and it’s federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions.
Finding 2024-012 – I. Procurement and Suspension and Debarment
Information on Federal Program(s) – Mission Support (ALN 43.009)
Criteria or Specific Requirement - The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition – The University did not maintain and use documented procurement procedures.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with federal procurement standards.
Questioned Costs – None.
Context – For 1 of 1 procurement transactions tested, the University was unable to provide records documenting appropriate vendor selection.
Indication of Repeat Finding – No similar findings identified in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that procurement transactions are appropriately documented.
Views of Responsible Officials – The University acknowledges that the required procurement procedures and controls were not followed. The University is developing a series of internal controls and procedures to ensure that procurement procedures and internal controls are designed and followed as required for all NIH and NASA grant procurements.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-007 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Federal-Work Study
Information on Federal Program(s) – Federal Work-Study Program (ALN 84.033)
Criteria or Specific Requirement – Federal regulations (34 CFR 675.19(b)) require institutions to establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid.
Condition – A certain student’s timesheet was not appropriately reviewed and approved.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs – None.
Context – 1 of 25 timesheets tested was not certified by the student’s supervisor.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that all Federal Work-Study related timesheets are appropriately reviewed and approved.
Views of Responsible Officials – The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed.
Each Monday the supervisor/manager must log into the student timecard and "approve" the card for the pay period that ended on the past Friday. When the supervisor/manager opens the card on Monday it defaults to the current pay period and not the previous pay period that needs to be approved. The supervisor/manager must select the "previous" pay period in order to approve the card to be processed.
In the case of the student in question, the supervisor/manager did not select the correct pay period and therefore approved the future timecard. As the payroll manager, I would have emailed him, the manager, that the card to be processed had not been approved. Upon that, he went back and approved the pay period that was to be processed. The approval on the next pay period that he mistakenly approved should have been removed. It was not. The process for card approvals is to check on the Monday of payroll the cards that are still in need of updates/corrections and approvals.
A report is run and shows what cards our still without approval and with errors. The payroll manager communicates to the manager and the student that there are errors on the card and/or it still needs to be approved. Payment for that card cannot be made until errors are corrected and the card is approved.
It is the supervisor and manager’s responsibility to ensure timecards are corrected and updated for processing. This error can be resolved with the supervisor/manager accountable for the accuracy of the time cards. Before processing a report, can be run by the payroll manager of the date/time of approval.
All supervisors and managers who are responsible for the approval of timecards will be reeducated on the process and sign off that they understand their role. Those who do not adhere to the process will have additional training. As new supervisors and managers are hired, the process will be part of their on-boarding.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-009 – N. Special Tests and Provisions – Perkins Loan Record Keeping and Record Retention
Information on Federal Program(s) - Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement - Institutions must retain original or true and exact copies of promissory and master promissory notes, repayment records, and cancellation and deferment requests for each Federal Perkins Loan Program (“Perkins”) loan made.
Condition – For certain Perkins loans, the University could not locate the original promissory notes that contained all the necessary information, including signatures. In addition, the University was unable to provide a listing of retired loans.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Perkins loan recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 10 of 40 borrowers tested, the University was unable to provide documentation evidencing proper retention of loan records.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-008.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure proper retention of Perkins loan records.
Views of Responsible Officials – Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information.
The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-002 – C. Cash Management
Information on Federal Program(s) - Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – An instance was identified where Title IV funds drawn were held in excess of the allowable time frame.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with Cash Management requirements.
Questioned Costs – None.
Context – During our audit procedures, we noted the following:
• 2 instances of cash held in excess of the allowable time frame for the Federal Pell Grant Program for the year ended June 30, 2024
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-004.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that excess cash is returned timely.
Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.
Finding 2024-004 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 2 of 40 disbursements tested, the University did not notify the borrower within the required timeframe. In addition, 2 of 40 notifications tested contained inaccurate disbursement dates.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-006.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-008 – L. Reporting – Financial Reporting
Information on Federal Program(s) – Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data.
Condition – For certain students identified through our testing, the University did not submit Federal Pell Grant Program payment data through the COD website within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds.
Questioned Costs – None.
Context – 2 of 25 disbursements tested were not reported within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure timely and accurate reporting of Federal Pell Grant Program payment data.
Views of Responsible Officials – Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and stay in compliance with the Department of Education reporting requirement regulation.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-003 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 3 of 40 campus level records and 1 of 40 program level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 3 of 40 campus level records and 9 of 40 program level records tested, the University did not accurately report all enrollment data elements.
• 36 of 97 error records identified during the year ended June 30, 2024 were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2023-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005 and 2023-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices.
Finding 2024-004 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 2 of 40 disbursements tested, the University did not notify the borrower within the required timeframe. In addition, 2 of 40 notifications tested contained inaccurate disbursement dates.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-006.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-011 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 7 of 8 employees tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-013.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document time and effort associated with research and development cluster and it’s federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions.
Finding 2024-011 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 7 of 8 employees tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-013.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document time and effort associated with research and development cluster and it’s federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions.
Finding 2024-012 – I. Procurement and Suspension and Debarment
Information on Federal Program(s) – Mission Support (ALN 43.009)
Criteria or Specific Requirement - The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition – The University did not maintain and use documented procurement procedures.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with federal procurement standards.
Questioned Costs – None.
Context – For 1 of 1 procurement transactions tested, the University was unable to provide records documenting appropriate vendor selection.
Indication of Repeat Finding – No similar findings identified in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that procurement transactions are appropriately documented.
Views of Responsible Officials – The University acknowledges that the required procurement procedures and controls were not followed. The University is developing a series of internal controls and procedures to ensure that procurement procedures and internal controls are designed and followed as required for all NIH and NASA grant procurements.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-007 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Federal-Work Study
Information on Federal Program(s) – Federal Work-Study Program (ALN 84.033)
Criteria or Specific Requirement – Federal regulations (34 CFR 675.19(b)) require institutions to establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid.
Condition – A certain student’s timesheet was not appropriately reviewed and approved.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs – None.
Context – 1 of 25 timesheets tested was not certified by the student’s supervisor.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that all Federal Work-Study related timesheets are appropriately reviewed and approved.
Views of Responsible Officials – The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed.
Each Monday the supervisor/manager must log into the student timecard and "approve" the card for the pay period that ended on the past Friday. When the supervisor/manager opens the card on Monday it defaults to the current pay period and not the previous pay period that needs to be approved. The supervisor/manager must select the "previous" pay period in order to approve the card to be processed.
In the case of the student in question, the supervisor/manager did not select the correct pay period and therefore approved the future timecard. As the payroll manager, I would have emailed him, the manager, that the card to be processed had not been approved. Upon that, he went back and approved the pay period that was to be processed. The approval on the next pay period that he mistakenly approved should have been removed. It was not. The process for card approvals is to check on the Monday of payroll the cards that are still in need of updates/corrections and approvals.
A report is run and shows what cards our still without approval and with errors. The payroll manager communicates to the manager and the student that there are errors on the card and/or it still needs to be approved. Payment for that card cannot be made until errors are corrected and the card is approved.
It is the supervisor and manager’s responsibility to ensure timecards are corrected and updated for processing. This error can be resolved with the supervisor/manager accountable for the accuracy of the time cards. Before processing a report, can be run by the payroll manager of the date/time of approval.
All supervisors and managers who are responsible for the approval of timecards will be reeducated on the process and sign off that they understand their role. Those who do not adhere to the process will have additional training. As new supervisors and managers are hired, the process will be part of their on-boarding.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-009 – N. Special Tests and Provisions – Perkins Loan Record Keeping and Record Retention
Information on Federal Program(s) - Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement - Institutions must retain original or true and exact copies of promissory and master promissory notes, repayment records, and cancellation and deferment requests for each Federal Perkins Loan Program (“Perkins”) loan made.
Condition – For certain Perkins loans, the University could not locate the original promissory notes that contained all the necessary information, including signatures. In addition, the University was unable to provide a listing of retired loans.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Perkins loan recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 10 of 40 borrowers tested, the University was unable to provide documentation evidencing proper retention of loan records.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-008.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure proper retention of Perkins loan records.
Views of Responsible Officials – Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information.
The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-002 – C. Cash Management
Information on Federal Program(s) - Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – An instance was identified where Title IV funds drawn were held in excess of the allowable time frame.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with Cash Management requirements.
Questioned Costs – None.
Context – During our audit procedures, we noted the following:
• 2 instances of cash held in excess of the allowable time frame for the Federal Pell Grant Program for the year ended June 30, 2024
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-004.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that excess cash is returned timely.
Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.
Finding 2024-004 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 2 of 40 disbursements tested, the University did not notify the borrower within the required timeframe. In addition, 2 of 40 notifications tested contained inaccurate disbursement dates.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-006.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-008 – L. Reporting – Financial Reporting
Information on Federal Program(s) – Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data.
Condition – For certain students identified through our testing, the University did not submit Federal Pell Grant Program payment data through the COD website within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds.
Questioned Costs – None.
Context – 2 of 25 disbursements tested were not reported within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure timely and accurate reporting of Federal Pell Grant Program payment data.
Views of Responsible Officials – Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and stay in compliance with the Department of Education reporting requirement regulation.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-003 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 3 of 40 campus level records and 1 of 40 program level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 3 of 40 campus level records and 9 of 40 program level records tested, the University did not accurately report all enrollment data elements.
• 36 of 97 error records identified during the year ended June 30, 2024 were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2023-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005 and 2023-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices.
Finding 2024-004 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition – Certain borrowers were not notified timely of Federal Direct Student Loans credited to their accounts.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements.
Questioned Costs – None.
Context – For 2 of 40 disbursements tested, the University did not notify the borrower within the required timeframe. In addition, 2 of 40 notifications tested contained inaccurate disbursement dates.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-006.
Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-005 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Return of funds was not properly calculated and returned.
Questioned Costs – Below reportable threshold.
Context – For 1 of 3 students tested, the University did not accurately determine the amount to return.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-016.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations.
Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2024-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Credit Balances
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379)
Criteria or Specific Requirement – Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class.
Condition – The University did not refund credit balances to certain students within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the federal guidelines over credit balances from student financial assistance.
Questioned Costs – None.
Context – 3 of 40 Title IV credit balances tested were not paid within the required timeframe.
Indication of Repeat Finding - No similar findings noted in the prior year.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely.
Views of Responsible Officials – The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future.
Finding 2024-010 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”)
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - An institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP.
Condition – The University submitted the 2023-2024 FISAP with errors and data corrections were not submitted by the required deadline.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, total tuition and fees as well as Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2023-2024 FISAP has closed; as of the date of our Single Audit report, these errors remain uncorrected as of the date of this report.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-010.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission.
Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future.
Finding 2024-011 – B. Allowable Costs/Cost Principles
Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859)
Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented.
Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with documentation of personnel expense standards.
Questioned Costs – Below reportable threshold.
Context – Context is as follows:
Expenditures: For 7 of 8 employees tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-013.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained.
Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document time and effort associated with research and development cluster and it’s federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions.