Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement – Procurement and Suspension and Debarment – (2 CFR
318 to 327, 2 CFR 180)
Condition - The University’s internal controls did not ensure that contracts entered into
with federal funds followed the procurement, suspension and debarment requirements.
Cause – The University’s policies did not ensure that costs for projects paid with federal
grant funds were not a cost plus percentage of profit or percentage of cost or that the
contractor was not suspended or debarred prior to entering into the contract.
Effect or potential effect – The University entered into a contract that was not in
accordance with the requirements of the Uniform Guidance.
Questioned costs - $223,526 calculated as the amount of the unallowed contract charged
to the grant.
Context – Out of the population of two contracts that were subject to procurement,
suspension and debarment, one contract was selected for testing. Our sampling
method was not, and was not intended to be, statistically valid. The price in the
contract was a percentage of cost. Additionally, there was no documentation ensuring
the contractor was not suspended or debarred.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their policies and controls to ensure
contracts entered into with federal funds meet the procurement, suspension and
debarment requirements.
Views of responsible officials and planned corrective actions – Management
acknowledges errors made in the procurement process related to contracting with the
architectural services vendor for the ARPA project. To address this, the University is in
the process of amending the contract to comply with 2 CFR requirements. Moving
forward, all federal construction projects will be bid and contracted using a fixed-cost
method. Additionally, the procurement process is being revised to include a vendor
review through SAM.gov prior to awarding contracts. This review will ensure that the
selected vendor is not suspended or debarred by the federal government at the time of
the award. University staff have attended multiple 2 CFR trainings hosted by the
Economic Development Administration and Maximus Higher Education. These sessions have been instrumental in equipping staff with the necessary knowledge to
manage future federally funded projects in compliance with regulations.
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement - Special Tests and Provisions – Verification (34 CFR
668.51 through 668.61) Institutions responsible for verifying applicant information for
those applicants selected by verification by the U.S. Department of Education.
Condition – The University’s processes did not ensure corrections were made to student
application data
Questioned costs - Unknown
Context – Out of the population of 281 students selected for verification, a sample of 25
students were selected for testing. Our sampling method was not, and was not
intended to be, statistically valid. The number of household members in college was
not correct on the student’s Institutional Student Information Record (ISIR) for two
students.
Effect – The student’s applicant data was not correct when used for packaging and
awarding aid
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure student data is
properly corrected on the students’ ISIRs in the verification process
Views of responsible officials and planned corrective actions – We did not verify that a
16-year-old household member listed on a verification form as “in college” was a
concurrent high school student due to the student’s age. The number in college
reported on the FASFA reflected what was believed to be accurate at the time. While
we are no longer required to verify the number in college, going forward, the University
will document any discrepancies to support determinations. To strengthen controls
around verification, the University will also document any changes made during the
verification process and provide supporting evidence for determinations. Additionally,
the University will conduct internal audits of the verification process and review the
cases of affected students.
Criteria or specific requirement – Procurement and Suspension and Debarment – (2 CFR
318 to 327, 2 CFR 180)
Condition - The University’s internal controls did not ensure that contracts entered into
with federal funds followed the procurement, suspension and debarment requirements.
Cause – The University’s policies did not ensure that costs for projects paid with federal
grant funds were not a cost plus percentage of profit or percentage of cost or that the
contractor was not suspended or debarred prior to entering into the contract.
Effect or potential effect – The University entered into a contract that was not in
accordance with the requirements of the Uniform Guidance.
Questioned costs - $223,526 calculated as the amount of the unallowed contract charged
to the grant.
Context – Out of the population of two contracts that were subject to procurement,
suspension and debarment, one contract was selected for testing. Our sampling
method was not, and was not intended to be, statistically valid. The price in the
contract was a percentage of cost. Additionally, there was no documentation ensuring
the contractor was not suspended or debarred.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their policies and controls to ensure
contracts entered into with federal funds meet the procurement, suspension and
debarment requirements.
Views of responsible officials and planned corrective actions – Management
acknowledges errors made in the procurement process related to contracting with the
architectural services vendor for the ARPA project. To address this, the University is in
the process of amending the contract to comply with 2 CFR requirements. Moving
forward, all federal construction projects will be bid and contracted using a fixed-cost
method. Additionally, the procurement process is being revised to include a vendor
review through SAM.gov prior to awarding contracts. This review will ensure that the
selected vendor is not suspended or debarred by the federal government at the time of
the award. University staff have attended multiple 2 CFR trainings hosted by the
Economic Development Administration and Maximus Higher Education. These sessions have been instrumental in equipping staff with the necessary knowledge to
manage future federally funded projects in compliance with regulations.