Audit 345963

FY End
2024-06-30
Total Expended
$33.24M
Findings
4
Programs
14
Organization: Bentley University (MA)
Year: 2024 Accepted: 2025-03-13
Auditor: Kpmg LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
526865 2024-001 Significant Deficiency Yes N
526866 2024-001 Significant Deficiency Yes N
1103307 2024-001 Significant Deficiency Yes N
1103308 2024-001 Significant Deficiency Yes N

Contacts

Name Title Type
N6DAMDJXFJ65 Donna Lane Auditee
7818912652 David Gagnon Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates. De Minimis Rate Used: N Rate Explanation: The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule. The accompanying supplementary schedule of expenditures of federal awards (the Schedule) summarizes the expenditures of Bentley University (the University) under programs funded by the federal government for the year ended June 30, 2024. The information in the 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 (the Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all federal assistance received directly from the federal government and awards passed through to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The Schedule also denotes awards passed through from the University to other nonfederal subrecipient organizations.
Title: Significant Accounting Policies Accounting Policies: Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates. De Minimis Rate Used: N Rate Explanation: The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule. Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates (note 3).
Title: Facilities and Administrative Cost Rate Accounting Policies: Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates. De Minimis Rate Used: N Rate Explanation: The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule. The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule.
Title: Federal Direct Loans Accounting Policies: Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates. De Minimis Rate Used: N Rate Explanation: The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule. The University distributed $25,864,836 of federally guaranteed loans to students of the University through the Federal Direct Loan Program (ALN 84.268), which includes Direct Subsidized and Unsubsidized Loans, and Direct Parent Loans for Undergraduate Students. These distributions and the related funding sources are not included in the University’s financial statements.
Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Accounting Policies: Expenditures for direct costs are recognized as incurred using the accrual basis of accounting and cost accounting principles of the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures also include a portion of costs associated with general University activities (facilities and administrative costs) which are allocated to awards under negotiated formulas commonly referred to as facilities and administrative cost rates. De Minimis Rate Used: N Rate Explanation: The University has an approved predetermined facilities and administrative cost rate effective through fiscal year June 30, 2024 for on-campus and off-campus sponsored program activities. As such, the University has not elected to use the federally allowed de minimis rate of 10%. The base rates in effect for the year ended June 30, 2024 were 59% of direct salaries for on-campus programs and 30.0% of direct salaries for off-campus programs. Facilities and administrative cost recoveries are reported as part of federal expenditures on the Schedule. The University received a disaster grant award in fiscal 2024 related to COVID-19. Expenditures included in the Schedule for Disaster Grants – Public Assistance (Presidentially Declared Disasters) (ALN 97.036) of $1,254,075 represent expenses incurred by the University prior to the year ended June 30, 2024.

Finding Details

Finding No.: 2024-001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified two (2) students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For one (1) student, the University was notified of the student’s enrollment status change from full-time to “Withdrew” in May 2024. Accordingly, the student’s’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was sixty-seven (67) days after the required submission date. • For one (1) student, the University placed the student on academic suspension on June 3, 2024. Accordingly, the students’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was fifty (50) days after the required submission date. Cause In both of these instances, the University’s summer enrollment reporting process of only reporting applicable changes for students enrolled in summer courses failed to identify these changes as neither student was enrolled in a summer course. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A portion of prior year finding 2023-001 related to issues affecting timeliness of enrollment reporting resulting from the University’s internal control processes not operating consistently to ensure that all enrollment changes, including transfers effective at the end of the semester, be submitted timely to NSLDS. Recommendation We recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the enrollment status changes for two students was due to the University's summer enrollment reporting process only reporting changes for students enrolled in summer courses. This process failed to identify status changes reported after the end of the spring semester when the student was not enrolled in the summer. As a result, the status change was not picked up for reporting until late summer. To address and prevent such issues in the future, the University has implemented enhanced controls to capture status changes outside of the term being reported. These measures, along with clearly defined procedures for managing enrollment reporting ensures the timely submission of status changes. Additionally, the University commits to conducting regular reviews and updates of its reporting processes to ensure compliance with federal requirements and to avoid potential delays in the future.
Finding No.: 2024-001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified two (2) students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For one (1) student, the University was notified of the student’s enrollment status change from full-time to “Withdrew” in May 2024. Accordingly, the student’s’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was sixty-seven (67) days after the required submission date. • For one (1) student, the University placed the student on academic suspension on June 3, 2024. Accordingly, the students’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was fifty (50) days after the required submission date. Cause In both of these instances, the University’s summer enrollment reporting process of only reporting applicable changes for students enrolled in summer courses failed to identify these changes as neither student was enrolled in a summer course. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A portion of prior year finding 2023-001 related to issues affecting timeliness of enrollment reporting resulting from the University’s internal control processes not operating consistently to ensure that all enrollment changes, including transfers effective at the end of the semester, be submitted timely to NSLDS. Recommendation We recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the enrollment status changes for two students was due to the University's summer enrollment reporting process only reporting changes for students enrolled in summer courses. This process failed to identify status changes reported after the end of the spring semester when the student was not enrolled in the summer. As a result, the status change was not picked up for reporting until late summer. To address and prevent such issues in the future, the University has implemented enhanced controls to capture status changes outside of the term being reported. These measures, along with clearly defined procedures for managing enrollment reporting ensures the timely submission of status changes. Additionally, the University commits to conducting regular reviews and updates of its reporting processes to ensure compliance with federal requirements and to avoid potential delays in the future.
Finding No.: 2024-001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified two (2) students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For one (1) student, the University was notified of the student’s enrollment status change from full-time to “Withdrew” in May 2024. Accordingly, the student’s’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was sixty-seven (67) days after the required submission date. • For one (1) student, the University placed the student on academic suspension on June 3, 2024. Accordingly, the students’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was fifty (50) days after the required submission date. Cause In both of these instances, the University’s summer enrollment reporting process of only reporting applicable changes for students enrolled in summer courses failed to identify these changes as neither student was enrolled in a summer course. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A portion of prior year finding 2023-001 related to issues affecting timeliness of enrollment reporting resulting from the University’s internal control processes not operating consistently to ensure that all enrollment changes, including transfers effective at the end of the semester, be submitted timely to NSLDS. Recommendation We recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the enrollment status changes for two students was due to the University's summer enrollment reporting process only reporting changes for students enrolled in summer courses. This process failed to identify status changes reported after the end of the spring semester when the student was not enrolled in the summer. As a result, the status change was not picked up for reporting until late summer. To address and prevent such issues in the future, the University has implemented enhanced controls to capture status changes outside of the term being reported. These measures, along with clearly defined procedures for managing enrollment reporting ensures the timely submission of status changes. Additionally, the University commits to conducting regular reviews and updates of its reporting processes to ensure compliance with federal requirements and to avoid potential delays in the future.
Finding No.: 2024-001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified two (2) students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For one (1) student, the University was notified of the student’s enrollment status change from full-time to “Withdrew” in May 2024. Accordingly, the student’s’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was sixty-seven (67) days after the required submission date. • For one (1) student, the University placed the student on academic suspension on June 3, 2024. Accordingly, the students’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was fifty (50) days after the required submission date. Cause In both of these instances, the University’s summer enrollment reporting process of only reporting applicable changes for students enrolled in summer courses failed to identify these changes as neither student was enrolled in a summer course. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A portion of prior year finding 2023-001 related to issues affecting timeliness of enrollment reporting resulting from the University’s internal control processes not operating consistently to ensure that all enrollment changes, including transfers effective at the end of the semester, be submitted timely to NSLDS. Recommendation We recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the enrollment status changes for two students was due to the University's summer enrollment reporting process only reporting changes for students enrolled in summer courses. This process failed to identify status changes reported after the end of the spring semester when the student was not enrolled in the summer. As a result, the status change was not picked up for reporting until late summer. To address and prevent such issues in the future, the University has implemented enhanced controls to capture status changes outside of the term being reported. These measures, along with clearly defined procedures for managing enrollment reporting ensures the timely submission of status changes. Additionally, the University commits to conducting regular reviews and updates of its reporting processes to ensure compliance with federal requirements and to avoid potential delays in the future.