Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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 National Student Loan Data System (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 accurately or timely reported to the NSLDS.
Questioned costs: None.
Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following:
• 4 out of 60 students were never reported to the NSLDS
• 20 out of 60 students’ change in status were not reported timely to the NSLDS
• 3 out of 60 students’ enrollment status were not being certified at least every 60 days within the NSLDS
• 12 out of 60 students’ program begin dates were reported incorrectly to the NSLDS
• 2 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records
• 5 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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 National Student Loan Data System (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 accurately or timely reported to the NSLDS.
Questioned costs: None.
Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following:
• 4 out of 60 students were never reported to the NSLDS
• 20 out of 60 students’ change in status were not reported timely to the NSLDS
• 3 out of 60 students’ enrollment status were not being certified at least every 60 days within the NSLDS
• 12 out of 60 students’ program begin dates were reported incorrectly to the NSLDS
• 2 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records
• 5 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 disbursements, we noted the following:
• 4 disbursement dates were incorrectly reported to COD
• 8 disbursements were not reported to COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect disbursement dates.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: Yes, 2023-004.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 disbursements, we noted the following:
• 4 disbursement dates were incorrectly reported to COD
• 8 disbursements were not reported to COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect disbursement dates.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: Yes, 2023-004.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.031C
Federal Award Identification Number and Year: P031C210072 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
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 had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made, and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2023-001.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Commerce
Federal Program Name: Connecting Minority Communities Pilot Program
Assistance Listing Number: 11.028
Federal Award Identification Number and Year: 3409C13052 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: In accordance with 47 CFR 302.9, each grant recipient shall submit semi-annual and annual performance reports to National Telecommunications and Information Administration (NTIA), following the procedures of 2 CFR 200.329.
Condition: During our review of the performance reports submitted for fiscal year 2024, we identified inaccuracies in the reported dollar amounts of expenditures for the period. The key line items affected were 3a, 5a, 5d, and 8a through 8k.
Questioned costs: None.
Context: During our testing of the 2 performance reports, it was noted that:
• 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d
• 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d and lines 8a through 8k reflected the incorrect period of the report
Cause: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Effect: The University did not report accurate information on performance reports submitted during the year.
Repeat finding: No.
Recommendation: We recommend the University review its procedures around completing and reviewing performance reports.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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 National Student Loan Data System (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 accurately or timely reported to the NSLDS.
Questioned costs: None.
Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following:
• 4 out of 60 students were never reported to the NSLDS
• 20 out of 60 students’ change in status were not reported timely to the NSLDS
• 3 out of 60 students’ enrollment status were not being certified at least every 60 days within the NSLDS
• 12 out of 60 students’ program begin dates were reported incorrectly to the NSLDS
• 2 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records
• 5 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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 National Student Loan Data System (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 accurately or timely reported to the NSLDS.
Questioned costs: None.
Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following:
• 4 out of 60 students were never reported to the NSLDS
• 20 out of 60 students’ change in status were not reported timely to the NSLDS
• 3 out of 60 students’ enrollment status were not being certified at least every 60 days within the NSLDS
• 12 out of 60 students’ program begin dates were reported incorrectly to the NSLDS
• 2 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records
• 3 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records
• 5 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 disbursements, we noted the following:
• 4 disbursement dates were incorrectly reported to COD
• 8 disbursements were not reported to COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect disbursement dates.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: Yes, 2023-004.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.063; 84.268
Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 disbursements, we noted the following:
• 4 disbursement dates were incorrectly reported to COD
• 8 disbursements were not reported to COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect disbursement dates.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: Yes, 2023-004.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but –
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Student Title IV credit balances were not refunded within the required 14-day time frame.
Questioned costs: None.
Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required.
Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation.
Questioned costs: $3,370
Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date.
Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used.
Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines.
Repeat finding: No.
Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.031C
Federal Award Identification Number and Year: P031C210072 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
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 had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made, and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2023-001.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Commerce
Federal Program Name: Connecting Minority Communities Pilot Program
Assistance Listing Number: 11.028
Federal Award Identification Number and Year: 3409C13052 - 2024
Award Period: July 01, 2023 - June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: In accordance with 47 CFR 302.9, each grant recipient shall submit semi-annual and annual performance reports to National Telecommunications and Information Administration (NTIA), following the procedures of 2 CFR 200.329.
Condition: During our review of the performance reports submitted for fiscal year 2024, we identified inaccuracies in the reported dollar amounts of expenditures for the period. The key line items affected were 3a, 5a, 5d, and 8a through 8k.
Questioned costs: None.
Context: During our testing of the 2 performance reports, it was noted that:
• 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d
• 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d and lines 8a through 8k reflected the incorrect period of the report
Cause: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment.
Effect: The University did not report accurate information on performance reports submitted during the year.
Repeat finding: No.
Recommendation: We recommend the University review its procedures around completing and reviewing performance reports.
Views of responsible officials: There is no disagreement with the audit finding.