Audit 349557

FY End
2024-06-30
Total Expended
$31.71M
Findings
6
Programs
12
Organization: Nazareth College of Rochester (NY)
Year: 2024 Accepted: 2025-03-28
Auditor: Bonadio & CO LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
538842 2024-003 Significant Deficiency - N
538843 2024-001 Significant Deficiency - N
538844 2024-002 Significant Deficiency - E
1115284 2024-003 Significant Deficiency - N
1115285 2024-001 Significant Deficiency - N
1115286 2024-002 Significant Deficiency - E

Contacts

Name Title Type
WBN8EADUR4H9 Karen Kuppinger Auditee
5853892020 Joseph Peplin Auditor
No contacts on file

Notes to SEFA

Title: General 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, wherein certain types of expenditures are not allowable or are limited as to reimbursement. For the purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government. Student financial aid includes certain awards to provide financial assistance to students, primarily under the Federal Work-Study, Pell Grant, and Supplemental Educational Opportunity Grant programs of the Department of Education. The University receives awards to make loans to eligible students under certain federal student loan programs and federally guaranteed loans are issued to students of the University by the federal government. These loans are considered for purposes of determining whether student financial aid is a major or non-major program. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Nazareth University (the University) under programs of the federal government for the year ended June 30, 2024, and has been prepared in accordance with accounting principles generally accepted in the United States of America. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, change in net assets, or cash flows of the University.
Title: Federal Student Loan Programs 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, wherein certain types of expenditures are not allowable or are limited as to reimbursement. For the purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government. Student financial aid includes certain awards to provide financial assistance to students, primarily under the Federal Work-Study, Pell Grant, and Supplemental Educational Opportunity Grant programs of the Department of Education. The University receives awards to make loans to eligible students under certain federal student loan programs and federally guaranteed loans are issued to students of the University by the federal government. These loans are considered for purposes of determining whether student financial aid is a major or non-major program. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Federal Perkins Loan Program is administered directly by the University and balances and transactions relating to this program are included in the University’s financial statements. The balance of loans outstanding under the Federal Perkins Loan Program was $370,110 at June 30, 2024.

Finding Details

Criteria – After a student withdraws and is determined to not have earned 100% of their Title IV funds, institutions are required to return the unearned portion of Title IV funds to DOE within 45 days of the institution determining that the student had withdrawn. Condition – Out of four withdrawals selected for testing, the University did not return one student’s portion of unearned Title IV funds until 56 days after it determined that the student had withdrawn. Cause – The University did not have effective controls in place to ensure that Title IV funds were returned within the 45 day window. Effect – The University was not in compliance with the DOE’s requirements for returning funds to the DOE. Recommendation – We recommend that the University assess and ensure that there are adequate resources and training available to handle Title IV fund returns timely. Additionally, we recommend the University develop policies and procedures to ensure timely processing of refunds View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. This responsibility has been assigned to a new individual who has the necessary training and experience to ensure that Return to Title IV refunds are completed in the required timeframe.
Criteria – Institutions are required, for each student whose application is selected by the U.S. Department of Education (DOE), to verify the information required for the verification tracking group to which the applicant is assigned. Condition – For one out of 40 students selected for testing, the University did not perform the required verification procedures. Cause – The University was required to verify the student’s and parents’ AGI, income taxes paid, additional income, and family size and family members attending college. Per the July 8, 2022 Federal Register, income information for tax filers is not required to be separately verified if the school identified the information as being obtained using the Internal Revenue System Data Retrieval Tool (IRS DRT) and the information was not changed. This student’s Institutional Student Information Record (ISIR) indicated that the student’s parents did not use the IRS DRT; however, the parents incorrectly indicated on their verification worksheet that they did use the IRS DRT. Although the parents reported incorrect information, the University is responsible for ensuring that the IRS DRT was used. As a result, the University failed to verify the required parents’ income information. Effect – The University was not in compliance with the DOE’s requirements for verification. Recommendation – We recommend that the University develop policies and procedures surrounding verification information that is reported on the ISIR in order to ensure verification is completed accurately. View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. The University provided additional training to financial aid staff to ensure review of student information received is completed accurately and agrees with the information provided on the student’s ISIR.
Criteria – According to federal regulations, institutions are required to calculate and disburse Pell and Teacher Education Assistance for College and Higher Education (TEACH) Grants to eligible students based on specific eligibility criteria. Condition – The University awarded more than the maximum allowed Pell Grant to one student, and more than the maximum allowed TEACH Grant to two students, from the sample of 40 students that were selected for testing. Cause – Human error resulted in the University over-awarding Pell and TEACH grants. Effect – The University did not properly disburse Pell or TEACH Grants, resulting in over awarding the affected students. Recommendation – We recommend that the University provide training to staff on identifying and resolving registration changes and exceeded annual grant limits impacting Pell and TEACH disbursements. We also recommend that the University enhance and monitor the effectiveness of controls to ensure timely and accurate adjustments to students’ disbursements in compliance with federal requirements. View of Responsible Officials – We agree with the auditor’s finding as set forth above. Due to turnover in the financial aid department, there was an incorrect understanding of the maximum award process. We have updated the University’s policies and procedures to ensure they are compliant with Title IV requirements and will be assigning this responsibility to a new employee. The University has refunded, through Common Origination and Disbursement, any federal funding associated with the over-awards as noted in this finding.
Criteria – After a student withdraws and is determined to not have earned 100% of their Title IV funds, institutions are required to return the unearned portion of Title IV funds to DOE within 45 days of the institution determining that the student had withdrawn. Condition – Out of four withdrawals selected for testing, the University did not return one student’s portion of unearned Title IV funds until 56 days after it determined that the student had withdrawn. Cause – The University did not have effective controls in place to ensure that Title IV funds were returned within the 45 day window. Effect – The University was not in compliance with the DOE’s requirements for returning funds to the DOE. Recommendation – We recommend that the University assess and ensure that there are adequate resources and training available to handle Title IV fund returns timely. Additionally, we recommend the University develop policies and procedures to ensure timely processing of refunds View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. This responsibility has been assigned to a new individual who has the necessary training and experience to ensure that Return to Title IV refunds are completed in the required timeframe.
Criteria – Institutions are required, for each student whose application is selected by the U.S. Department of Education (DOE), to verify the information required for the verification tracking group to which the applicant is assigned. Condition – For one out of 40 students selected for testing, the University did not perform the required verification procedures. Cause – The University was required to verify the student’s and parents’ AGI, income taxes paid, additional income, and family size and family members attending college. Per the July 8, 2022 Federal Register, income information for tax filers is not required to be separately verified if the school identified the information as being obtained using the Internal Revenue System Data Retrieval Tool (IRS DRT) and the information was not changed. This student’s Institutional Student Information Record (ISIR) indicated that the student’s parents did not use the IRS DRT; however, the parents incorrectly indicated on their verification worksheet that they did use the IRS DRT. Although the parents reported incorrect information, the University is responsible for ensuring that the IRS DRT was used. As a result, the University failed to verify the required parents’ income information. Effect – The University was not in compliance with the DOE’s requirements for verification. Recommendation – We recommend that the University develop policies and procedures surrounding verification information that is reported on the ISIR in order to ensure verification is completed accurately. View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. The University provided additional training to financial aid staff to ensure review of student information received is completed accurately and agrees with the information provided on the student’s ISIR.
Criteria – According to federal regulations, institutions are required to calculate and disburse Pell and Teacher Education Assistance for College and Higher Education (TEACH) Grants to eligible students based on specific eligibility criteria. Condition – The University awarded more than the maximum allowed Pell Grant to one student, and more than the maximum allowed TEACH Grant to two students, from the sample of 40 students that were selected for testing. Cause – Human error resulted in the University over-awarding Pell and TEACH grants. Effect – The University did not properly disburse Pell or TEACH Grants, resulting in over awarding the affected students. Recommendation – We recommend that the University provide training to staff on identifying and resolving registration changes and exceeded annual grant limits impacting Pell and TEACH disbursements. We also recommend that the University enhance and monitor the effectiveness of controls to ensure timely and accurate adjustments to students’ disbursements in compliance with federal requirements. View of Responsible Officials – We agree with the auditor’s finding as set forth above. Due to turnover in the financial aid department, there was an incorrect understanding of the maximum award process. We have updated the University’s policies and procedures to ensure they are compliant with Title IV requirements and will be assigning this responsibility to a new employee. The University has refunded, through Common Origination and Disbursement, any federal funding associated with the over-awards as noted in this finding.