FAC Explorer

Audit 348667

FY End
2024-06-30
Total Expended
$648.71M
Findings
10
Programs
131
Organization: State System of Higher Education, Commonwealth of Pennsylvania (PA)
Year: 2024 Accepted: 2025-03-26
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
537456 2024-001 Significant Deficiency Yes N
537457 2024-001 Significant Deficiency Yes N
537458 2024-002 Significant Deficiency Yes N
537459 2024-002 Significant Deficiency Yes N
537460 2024-003 Significant Deficiency - N
1113898 2024-001 Significant Deficiency Yes N
1113899 2024-001 Significant Deficiency Yes N
1113900 2024-002 Significant Deficiency Yes N
1113901 2024-002 Significant Deficiency Yes N
1113902 2024-003 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $455.00M Yes 3
84.063 Federal Pell Grant Program $124.44M Yes 2
93.575 Child Care and Development Block Grant $8.15M Yes 0
84.033 Federal Work-Study Program $5.19M Yes 0
93.917 Hiv Care Formula Grants $4.39M - 0
84.011 Migrant Education_state Grant Program $3.99M - 0
84.038 Federal Perkins Loan Program $3.67M Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $3.60M Yes 0
84.042 Trio_student Support Services $2.64M Yes 0
47.076 Education and Human Resources $2.54M - 0
84.047 Trio_upward Bound $1.86M Yes 0
17.504 Consultation Agreements $1.51M Yes 0
84.048 Career and Technical Education -- Basic Grants to States $1.27M Yes 0
93.600 Head Start $1.26M - 0
84.044 Trio_talent Search $700,594 Yes 0
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $607,667 - 0
12.902 Information Security Grants $545,208 - 0
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $523,464 - 0
84.149 Migrant Education_college Assistance Migrant Program $486,717 - 0
84.215 Fund for the Improvement of Education $465,096 - 0
84.407 Transition Programs for Students with Intellectual Disabilities Into Higher Education $405,416 - 0
12.357 National Fish and Wildlife Foundation $380,965 - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $329,487 - 0
47.083 Integrative Activities $320,463 - 0
21.031 State Small Business Credit Initiative Technical Assistance Grant Program $313,136 - 0
93.191 Graduate Psychology Education Program and Patient Navigator and Chronic Disease Prevention Program $307,245 - 0
93.364 Nursing Student Loans $304,975 Yes 0
84.031 Higher Education_institutional Aid $275,742 - 0
47.076 Stem Education (formerly Education and Human Resources) $265,044 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $244,796 - 0
84.335 Child Care Access Means Parents in School $239,631 - 0
12.905 Cybersecurity Core Curriculum $217,988 - 0
16.550 State Justice Statistics Program for Statistical Analysis Centers $217,976 - 0
93.958 Block Grants for Community Mental Health Services $215,052 - 0
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $214,260 - 0
11.008 Noaa Mission-Related Education Awards $196,086 - 0
84.116 Fund for the Improvement of Postsecondary Education $192,854 - 0
12.006 National Defense Education Program $192,247 - 0
84.031 Higher Education Institutional Aid $170,613 - 0
93.279 Drug Abuse and Addiction Research Programs $165,908 - 0
47.041 Engineering $164,016 - 0
12.300 Basic and Applied Scientific Research $138,071 - 0
93.276 Drug-Free Communities Support Program Grants $125,281 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $125,126 - 0
11.307 Economic Adjustment Assistance $122,745 - 0
17.502 Occupational Safety and Health_susan Harwood Training Grants $122,247 - 0
47.049 Mathematical and Physical Sciences $116,194 - 0
47.079 Office of International Science and Engineering $108,162 - 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $107,030 Yes 0
84.027 Special Education_grants to States $106,438 - 0
81.049 Office of Science Financial Assistance Program $99,128 - 0
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $96,923 - 0
10.558 Child and Adult Care Food Program $92,443 - 0
84.027 Special Education Grants to States $86,603 - 0
20.600 State and Community Highway Safety $83,508 - 0
10.001 Agricultural Research_basic and Applied Research $78,804 - 0
66.708 Pollution Prevention Grants Program $75,178 - 0
12.002 Procurement Technical Assistance for Business Firms $73,720 - 0
93.173 Research Related to Deafness and Communication Disorders $72,142 - 0
12.903 Gencyber Grants Program $69,374 - 0
45.024 Promotion of the Arts_grants to Organizations and Individuals $68,831 - 0
20.U04 Little Daniels Run Mitigation $68,781 - 0
17.278 Wioa Dislocated Worker Formula Grants $66,338 - 0
45.313 Laura Bush 21st Century Librarian Program $65,801 - 0
64.034 Va Assistance to United States Paralympic Integrated Adaptive Sports Program $65,605 - 0
59.037 Small Business Development Centers $64,344 - 0
16.575 Crime Victim Assistance $60,046 - 0
17.258 Wioa Adult Program $57,385 - 0
15.634 State Wildlife Grants $56,959 - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $51,682 - 0
16.812 Second Chance Act Reentry Initiative $49,963 - 0
10.310 Agriculture and Food Research Initiative (afri) $48,504 - 0
47.074 Biological Sciences $45,656 - 0
17.280 Wioa Dislocated Worker National Reserve Demonstration Grants $44,828 - 0
93.262 Occupational Safety and Health Program $41,088 - 0
15.904 Historic Preservation Fund Grants-in-Aid $39,930 - 0
93.732 Mental and Behavioral Health Education and Training Grants $39,663 Yes 0
93.264 Nurse Faculty Loan Program (nflp) $37,550 Yes 0
47.075 Social, Behavioral, and Economic Sciences $36,914 - 0
23.002 Appalachian Area Development $36,831 - 0
12.U01 Strategic Environment Research and Development Program-Lock Haven $36,718 - 0
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $35,000 - 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $32,377 - 0
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $30,548 - 0
84.425 Education Stabilization Fund $30,000 - 0
12.740 Past Conflict Accounting $29,707 - 0
81.123 National Nuclear Security Administration (nnsa) Minority Serving Institutions (msi) Program $28,387 - 0
93.599 Chafee Education and Training Vouchers Program (etv) $28,202 - 0
19.009 Academic Exchange Programs - Undergraduate Programs $26,219 - 0
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $26,216 - 0
17.289 Community Project Funding/congressionally Directed Spending $26,085 - 0
15.945 Cooperative Research and Training Programs Ð Resources of the National Park System $22,947 - 0
10.912 Environmental Quality Incentives Program $21,252 - 0
16.710 Public Safety Partnership and Community Policing Grants $18,553 - 0
93.859 Biomedical Research and Research Training $18,272 - 0
15.662 Great Lakes Restoration $16,267 - 0
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $15,177 - 0
93.172 Human Genome Research $14,617 - 0
47.050 Geosciences $14,373 - 0
93.124 Nurse Anesthetist Traineeships $14,130 - 0
45.024 Promotion of the Arts Grants to Organizations and Individuals $13,000 - 0
15.946 Cultural Resources Management $12,509 - 0
93.630 Developmental Disabilities Basic Support and Advocacy Grants $11,712 - 0
43.008 Education $11,614 - 0
93.788 Opioid Str $11,211 - 0
20.U03 Ralston Run/ashton Dam $10,039 - 0
11.457 Chesapeake Bay Studies $8,742 - 0
23.001 Appalachian Regional Development (see Individual Appalachian Programs) $8,512 - 0
43.008 Office of Stem Engagement (ostem) $8,263 - 0
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $8,000 - 0
10.025 Plant and Animal Disease, Pest Control, and Animal Care $7,365 - 0
20.U02 Marchezak Farm Stream Mitigation Project II $5,758 - 0
15.670 Adaptive Science $5,722 - 0
84.351 Arts in Education $5,369 - 0
10.559 Summer Food Service Program for Children $4,596 - 0
12.005 Conservation and Rehabilitation of Natural Resources on Military Installations $4,409 - 0
66.717 Source Reduction Assistance $3,586 - 0
15.954 National Park Service Conservation, Protection, Outreach, and Education $3,500 - 0
10.699 Partnership Agreements $2,510 - 0
19.408 Academic Exchange Programs - Teachers $2,313 - 0
15.815 National Land Remote Sensing_education Outreach and Research $2,104 - 0
93.884 Primary Care Training and Enhancement $1,593 - 0
15.657 Endangered Species Recovery Implementation $800 - 0
64.U01 Va-Once $774 - 0
12.U01 2024 Communities Talk to Prevent Underage Drinking Award $750 - 0
20.U01 Wetlands Mitigation Project $471 - 0
21.019 Coronavirus Relief Fund $371 - 0
15.663 Nfwf-Usfws Conservation Partnership $274 - 0
14.241 Housing Opportunities for Persons with Aids $215 - 0
15.255 Science and Technology Projects Related to Coal Mining and Reclamation $164 - 0
47.078 Polar Programs $23 - 0

Contacts

Name Title Type
QG9HTDGKJJL3 Christa Porter Auditee
7177204124 Andrew Lee Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. The State System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: See above. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) represents a summary of federal awards expended by the Pennsylvania State System of Higher Education, Commonwealth of Pennsylvania (the State System), and its member universities, for the year ended June 30, 2024. For purposes of the Schedule, federal awards include all U.S. government financial assistance, procurement relationships between the State System and its member universities and the federal government, and subawards made under federally sponsored agreements that are received from nonfederal organizations. The Schedule classifies the expenditures of federal awards into two categories: Research & Development Cluster and Other Federal Awards. Within each category, federal awards have been classified as either direct (awards received directly from a federal agency) or pass through (subawards received from nonfederal organizations that were made under federally sponsored agreements). The State System recognizes expenditures of federal program funds on the accrual basis of accounting.
Title: Student Financial Assistance Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. The State System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: See above. The following table shows certain information concerning student financial assistance programs detailed by University for the year ended June 30, 2024: The above amounts awarded to students include certain administrative allowances. The State System participates in the following student loan programs: Federal Perkins Loan Program (AL No. 84.038); Nursing Student Loan Program (AL NO. 93.364); and Federal Direct Loan Program (AL No. 84.268), which includes the Federal Stafford Loan Program, the Federal Supplemental Loan for Students Program (SLS), and the Federal Parent Loans for Undergraduate Students Program (PLUS). Federal Perkins Loans and Nursing Student Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. Federal Perkins Loans and Nursing Student Loans awarded are included as part of Federal Perkins Loans and Nursing Student Loans Program on the schedule of expenditures of federal awards. Loans awarded under these programs for the year ended June 30, 2024 are as follows: Outstanding loans under the programs administered by the State System as of June 30, 2024 are as follows:
Title: Federal Student Loan Program Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. The State System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: See above. Loans outstanding at the beginning of the year are presented in the Schedule. During the year ended June 30, 2024, Kutztown University, Slippery Rock University, and Pennwest – Edinboro completed the liquidation of the Perkins Loan Program. All loans were properly assigned and accepted by the Department of Education
Title: STUDENT FINANCIAL AID AND INSTITUTIONAL PROGRAM ELIGIBILITY METRICS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. The State System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: See above. The Universities are in compliance with the following institutional and program eligibility requirements under the Higher Education Act of 1965 and Federal regulations under 34 CFR 668.23: -Correspondence courses the institution offers under 34 CFR 600.7(b) and (g) -Regular students that enroll in correspondence courses under 34 CFR 600.7(b) and (g) -Institution’s regular students that are incarcerated under 34 CFR 600.7(c) and (g) Completion rates for confined or incarcerated individuals enrolled in non-degree programs at nonprofit institutions under 34 CFR 600.7(c)(3)(ii) and (g) - Institution’s regular students that lack a high school diploma or its equivalent under 34 CFR 600.7(d) and (g) - Completion rates for short-term programs under 34 CFR 668.8(f) and (g) - Placement rates for short-term programs under https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.8 34 CFR 668.8(e)(2)

Finding Details

Finding 2024-001
2024 – 001 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years. Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change received by NSLDS was outside of the 60-day time frame. • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 9 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 35 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 3 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 10 of the 40 students tested for award year 2023-24 2) Enrollment was not certified at a minimum of every 60 days or every other month. • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 23 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2023-002 Kutztown University – Yes – Finding 2022-002 East Stroudsburg University – Yes – Finding 2023-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years. Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change received by NSLDS was outside of the 60-day time frame. • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 9 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 35 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 3 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 10 of the 40 students tested for award year 2023-24 2) Enrollment was not certified at a minimum of every 60 days or every other month. • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 23 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2023-002 Kutztown University – Yes – Finding 2022-002 East Stroudsburg University – Yes – Finding 2023-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 2 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 3 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 2 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 22 of the 40 students tested for award year 2023-24 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 12 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 3 of the 40 students tested for the award year 2023-24. 3) Incorrect Program Enrollment Status Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 4 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student’s program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student’s program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 East Stroudsburg - Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 Commonwealth University (Lock Haven University) – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 2 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 3 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 2 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 22 of the 40 students tested for award year 2023-24 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 12 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 3 of the 40 students tested for the award year 2023-24. 3) Incorrect Program Enrollment Status Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 4 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student’s program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student’s program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 East Stroudsburg - Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 Commonwealth University (Lock Haven University) – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K242129, P268K252129; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During the testing of Direct Loan Reconciliations on the State System, we noted that Commonwealth University was performing reconciliations; however, formal documentation of review or approval could not be provided. Questioned Costs: N/A Cause: The University financial and student records management did not have the appropriate coordination or communication with the financial aid team to formally document the review of the reconciliations being performed on a timely basis. Effect: The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled. Repeat Finding: No Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years. Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change received by NSLDS was outside of the 60-day time frame. • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 9 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 35 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 3 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 10 of the 40 students tested for award year 2023-24 2) Enrollment was not certified at a minimum of every 60 days or every other month. • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 23 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2023-002 Kutztown University – Yes – Finding 2022-002 East Stroudsburg University – Yes – Finding 2023-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years. Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change received by NSLDS was outside of the 60-day time frame. • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 9 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 35 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 3 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 10 of the 40 students tested for award year 2023-24 2) Enrollment was not certified at a minimum of every 60 days or every other month. • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 23 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 2 of the 5 students tested for award year 2023-24 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2023-002 Kutztown University – Yes – Finding 2022-002 East Stroudsburg University – Yes – Finding 2023-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 2 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 3 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 2 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 22 of the 40 students tested for award year 2023-24 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 12 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 3 of the 40 students tested for the award year 2023-24. 3) Incorrect Program Enrollment Status Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 4 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student’s program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student’s program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 East Stroudsburg - Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 Commonwealth University (Lock Haven University) – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 2 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 3 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 2 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 22 of the 40 students tested for award year 2023-24 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 12 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 3 of the 40 students tested for the award year 2023-24. 3) Incorrect Program Enrollment Status Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 4 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student’s program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student’s program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 East Stroudsburg - Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 Commonwealth University (Lock Haven University) – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K242129, P268K252129; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During the testing of Direct Loan Reconciliations on the State System, we noted that Commonwealth University was performing reconciliations; however, formal documentation of review or approval could not be provided. Questioned Costs: N/A Cause: The University financial and student records management did not have the appropriate coordination or communication with the financial aid team to formally document the review of the reconciliations being performed on a timely basis. Effect: The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled. Repeat Finding: No Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. Views of Responsible Officials: There is no disagreement with the audit finding.