FAC Explorer

Audit 348651

FY End
2024-06-30
Total Expended
$21.05M
Findings
22
Programs
16
Organization: Saint Peter's University and Affiliates (NJ)
Year: 2024 Accepted: 2025-03-26
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
537443 2024-001 Significant Deficiency Yes N
537444 2024-001 Significant Deficiency Yes N
537445 2024-001 Significant Deficiency Yes N
537446 2024-001 Significant Deficiency Yes N
537447 2024-002 Significant Deficiency Yes N
537448 2024-002 Significant Deficiency Yes N
537449 2024-002 Significant Deficiency Yes N
537450 2024-002 Significant Deficiency Yes N
537451 2024-002 Significant Deficiency Yes N
537452 2024-002 Significant Deficiency Yes N
537453 2024-003 Significant Deficiency - I
1113885 2024-001 Significant Deficiency Yes N
1113886 2024-001 Significant Deficiency Yes N
1113887 2024-001 Significant Deficiency Yes N
1113888 2024-001 Significant Deficiency Yes N
1113889 2024-002 Significant Deficiency Yes N
1113890 2024-002 Significant Deficiency Yes N
1113891 2024-002 Significant Deficiency Yes N
1113892 2024-002 Significant Deficiency Yes N
1113893 2024-002 Significant Deficiency Yes N
1113894 2024-002 Significant Deficiency Yes N
1113895 2024-003 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $6.81M Yes 2
84.287 Twenty-First Century Community Learning Centers $468,785 - 0
84.007 Federal Supplemental Educational Opportunity Grants $380,885 Yes 1
84.033 Federal Work-Study Program $377,763 Yes 1
64.027 Post-9/11 Veterans Educational Assistance $353,205 - 0
84.042 Trio Student Support Services $270,957 - 0
84.268 Federal Direct Student Loans $182,544 Yes 2
64.125 Vocational and Educational Counseling for Servicemembers and Veterans $157,022 - 0
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $129,429 - 0
84.116 Fund for the Improvement of Postsecondary Education $108,000 - 0
84.031 Higher Education Institutional Aid $105,908 - 0
47.076 Stem Education (formerly Education and Human Resources) $67,693 - 0
84.425 Education Stabilization Fund $51,282 - 0
97.024 Emergency Food and Shelter National Board Program $19,293 - 0
84.184 School Safely National Activities $16,080 - 0
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $13,138 - 0

Contacts

Name Title Type
JQQDRDJSWFE1 Vanessa Munoz Auditee
2017617433 Sara Doyle Auditor
No contacts on file

Notes to SEFA

Title: DIRECT LOAN PROGRAM Accounting Policies: BASIS OF PRESENTATION The accompanying schedules of expenditures of federal awards and state financial assistance include the federal and state award activity of the University under programs of the federal and New Jersey state government for the year ended June 30, 2024. The information in these schedules 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) and State of New Jersey, Department of the Treasury, OMB Circular 15-08 (New Jersey Circular 15 08). Because the schedules present only a selected portion of the operations of the University, they are not intended to and do not present the financial position, changes in net assets, or cash flows of the University. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedules of expenditures of federal awards and state financial assistance are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and New Jersey Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has a federally negotiated indirect cost rate and uses the 10% de minimis cost rate on certain grants. The University is responsible only for the performance of certain administrative duties with respect to the Federal Direct Student Loan Program (the Program) and, accordingly, the loans under the Program are not included in the consolidated financial statements. Loan amounts included in the schedule of expenditures of federal awards represent only new loans advanced in the current year. It is not practical to determine the balance of loans outstanding to students of the University under these programs at June 30, 2024.
Title: STUDENT FINANCIAL AID INSTITUTIONAL AND PROGRAM ELIGIBILITY METRICS Accounting Policies: BASIS OF PRESENTATION The accompanying schedules of expenditures of federal awards and state financial assistance include the federal and state award activity of the University under programs of the federal and New Jersey state government for the year ended June 30, 2024. The information in these schedules 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) and State of New Jersey, Department of the Treasury, OMB Circular 15-08 (New Jersey Circular 15 08). Because the schedules present only a selected portion of the operations of the University, they are not intended to and do not present the financial position, changes in net assets, or cash flows of the University. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedules of expenditures of federal awards and state financial assistance are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and New Jersey Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has a federally negotiated indirect cost rate and uses the 10% de minimis cost rate on certain grants. The Institution 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-668.834 CFR 668.8(e)(2)

Finding Details

Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: STEM - PODER Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210076-23; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: No. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-003
Federal Agency: U.S. Department of Education Federal Program Name: STEM - PODER Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210076-23; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: No. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.