Audit 344144

FY End
2024-05-31
Total Expended
$49.78M
Findings
8
Programs
24
Organization: Norwich University (VT)
Year: 2024 Accepted: 2025-02-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
524713 2024-001 Significant Deficiency - N
524714 2024-001 Significant Deficiency - N
524715 2024-001 Significant Deficiency - N
524716 2024-001 Significant Deficiency - N
1101155 2024-001 Significant Deficiency - N
1101156 2024-001 Significant Deficiency - N
1101157 2024-001 Significant Deficiency - N
1101158 2024-001 Significant Deficiency - N

Contacts

Name Title Type
VFQPWNA7EJF8 Leroy Young Auditee
8024852043 David Jacobson Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Federal Assistance Listing Number 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the University under programs of the federal government for the year ended May 31, 2024. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the basic financial statements. The schedule of expenditures of federal awards excludes the federal grant activity of Norwich University Applied Research Institute.
Title: Federal Loan Programs Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Federal Assistance Listing Number 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The federal student loan programs listed subsequently are administered directly by the University, and balances and transactions relating to these programs are included in the University’s basic financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the schedule. Outstanding loans as of May 31, 2024 are as follows: Federal Perkins Loan Program, Federal Assistance Listing No. 84.038, Outstanding Loan Balance $1,422,304 Nurse Faculty Loan Program, Federal Assistance Listing No. 93.264, Outstanding Loan Balance $117,291
Title: Student Financial Aid and Institutional Program Eligibility Metrics Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Federal Assistance Listing Number 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The University is in compliance with the following institutional and program eligibility requirements under the Higher Education Act of 1965 and Federal regulations under 34 CFR 668.23: • Correspondence courses the institution offers under 34 CFR 600.7(b) and (g) • Regular students that enroll in correspondence courses under 34 CFR 600.7(b) and (g) • Institution’s regular students that are incarcerated under 34 CFR 600.7(c) and (g) • Completion rates for confined or incarcerated individuals enrolled in non-degree programs at nonprofit institutions under 34 CFR 600.7(c)(3)(ii) and (g) • Institution’s regular students that lack a high school diploma or its equivalent under 34 CFR 600.7(d) and (g) • Completion rates for short-term programs under 34 CFR 668.8(f) and (g) • Placement rates for short-term programs under https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.8 34 CFR 668.8(e)(2)

Finding Details

Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.