Audit 345761

Finding 2024-002: Reporting - Schedule of Expenditures of Federal Awards Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.352 Title: A Washington University Gnotobiotic Research, Education and Transgenic Center for modeling genetic and environmental effectors of disease pathogenesis Award Year: 9/20/2019-5/31/2024 Award #: 1C06OD02830601 Criteria: 2 CFR 200.510 which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements that includes the total federal awards expenses. Condition: Expenditures totaling $2,013,944 related to a construction grant were incurred in prior fiscal years but recorded in the SEFA during the current fiscal year. Cause: The management of the construction grant activity resided in a department other than Sponsored Projects Accounting. Therefore, the grant was excluded from the normal processes for capturing activity in the SEFA. Effect: The current year SEFA is overstated by amounts that should have been recorded in the SEFA in prior years. Questioned Costs: There are no questioned costs as amounts sampled from the expenditures recorded in the current year SEFA were deemed allowable. Recommendation: Management should enhance its coordination and review procedures for special purpose grants managed outside of Sponsored Projects Accounting to ensure that amounts associated with such grants are completely and accurately reported in the SEFA. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-002: Reporting - Schedule of Expenditures of Federal Awards Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.352 Title: A Washington University Gnotobiotic Research, Education and Transgenic Center for modeling genetic and environmental effectors of disease pathogenesis Award Year: 9/20/2019-5/31/2024 Award #: 1C06OD02830601 Criteria: 2 CFR 200.510 which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements that includes the total federal awards expenses. Condition: Expenditures totaling $2,013,944 related to a construction grant were incurred in prior fiscal years but recorded in the SEFA during the current fiscal year. Cause: The management of the construction grant activity resided in a department other than Sponsored Projects Accounting. Therefore, the grant was excluded from the normal processes for capturing activity in the SEFA. Effect: The current year SEFA is overstated by amounts that should have been recorded in the SEFA in prior years. Questioned Costs: There are no questioned costs as amounts sampled from the expenditures recorded in the current year SEFA were deemed allowable. Recommendation: Management should enhance its coordination and review procedures for special purpose grants managed outside of Sponsored Projects Accounting to ensure that amounts associated with such grants are completely and accurately reported in the SEFA. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Finding 2024-001: Special Tests and Provisions – Disbursements to or on Behalf of Students, Enrollment Reporting, and Return of Title IV Funds Grantor: Department of Education Program: Student Financial Aid Cluster Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Year: 7/1/2023-6/30/2024 Award #: N/A Criteria: -34 CFR 668.165 which requires the institution to obtain the student's voluntary consent to participate in electronic transactions. -34 CFR 668.41 which notes an institution annually must distribute to all enrolled students a notice of the availability of the information required to be disclosed under the notification requirements of the Family Educational Rights and Privacy Act of 1974. -34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) amount of funds the student can expect to receive from each Federal Student Aid (FSA) program and (2) how and when those funds will be disbursed. -34 CFR Section 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Student status changes are required to be reported at both the "Campus Level" and "Program-Level" as each have separate record types. -34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. Condition: -Disbursements to or on behalf of students For 21 of 25 students sampled, the University was unable to provide evidence of each student's affirmative consent for electronic communications. For 25 of 25 students sampled, the University was unable to provide evidence that each student received notification of the availability of the Annual Security Report and Annual Fire Safety Report as required under the Clery Act. For 1 of 25 students sampled, the University was unable to evidence that they provided the student with their general award notification which includes the amount of funds expected to be received and timing of disbursement. -Enrollment reporting For 1 of 25 students sampled, the student's change in enrollment status was not reported to the National Student Loan Data System (NSLDS) within the 60 day required timeframe. -Return of Title IV funds For 1 of 6 students sampled, the University did not complete a return of Title IV funding worksheet to determine whether financial aid funding was required to be returned to the Department of Education. Cause: The University's experienced turnover in the Student Financial Aid Office as well as other offices that support the University's ongoing compliance within the Student Financial Assistance regulations. Additionally, the absence of a secondary level of review impacted the University's ability to ensure compliance with federal regulations. Effect: The University was unable to demonstrate compliance with certain required federal regulations. Questioned Costs: There are no questioned costs associated with this finding as the finding primarily relates to required student notifications and reporting. As it specifically relates to the Return of Title IV funds exception, no questioned costs were noted as there were no amounts that were required to be returned to the Department of Education. Recommendation: Management should cross train individuals within the Student Financial Aid Office as well as other offices that support financial aid administration to ensure the University is able to remain compliant with federal regulations during periods of turnover in personnel. Separately, the University should implement a process for reminders, secondary review, and follow up to ensure reporting obligations are met timely, completely, and accurately. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.