Audit 349948

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2024 – 002 – Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 170, as required by the Federal Funding Accountability and Transparency Act of 2006, states organizations which make subawards of federal funding with obligations of $25,000 or greater must complete FFATA reporting of executive compensation to the federal agency no later than the end of the month following the month in which the subaward obligation was made. Condition: During our testing, the University reported that they had not completed the required FFATA reporting for any of the subawards made during the year ended June 30, 2024 nor subsequent to year end. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place for ensuring completion of the FFATA reporting for subawards and sub awardee executive compensation as required in the federal fund notice of awards. Cause: UST was not aware of the timing of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed. Effect: By not completing the required FFATA reporting, the University is not in compliance with the terms of the award. This did not result in any disallowed costs. Repeat Finding: No. Recommendation: We recommend the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Views of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or Specific Requirement: Under the Uniform Guidance, nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: We tested five subrecipients paid over $25,000. One of the five tested did not have any documentation to support that the University verified the subrecipient was not suspended or debarred at the time of executing the subaward agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the subrecipient was neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation retained to ensure the SAM verification was done prior to executing the subaward agreement. In addition, there was no documentation of a second review to ensure the subrecipient was not suspended or debarred. Cause: The control system to prevent payment to a suspended and debarred vendor was not in place. Effect: The University could have entered into a covered transaction with a subrecipient who is suspended or debarred. Repeat Finding: No. Recommendation: We recommend the University review its existing policies to ensure it is up to date with federal regulations. We also recommend documenting the subrecipient was checked on the SAM.gov website prior to executing the subaward agreement. A secondary review should be performed prior to payment. This second review should be documented and retained to support the suspension and debarment requirements were followed and completed before entering into a covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 685.309 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. In addition, regulations require the status include an accurate effective date. 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. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.

2024 – 002 – Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 170, as required by the Federal Funding Accountability and Transparency Act of 2006, states organizations which make subawards of federal funding with obligations of $25,000 or greater must complete FFATA reporting of executive compensation to the federal agency no later than the end of the month following the month in which the subaward obligation was made. Condition: During our testing, the University reported that they had not completed the required FFATA reporting for any of the subawards made during the year ended June 30, 2024 nor subsequent to year end. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place for ensuring completion of the FFATA reporting for subawards and sub awardee executive compensation as required in the federal fund notice of awards. Cause: UST was not aware of the timing of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed. Effect: By not completing the required FFATA reporting, the University is not in compliance with the terms of the award. This did not result in any disallowed costs. Repeat Finding: No. Recommendation: We recommend the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Views of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or Specific Requirement: Under the Uniform Guidance, nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: We tested five subrecipients paid over $25,000. One of the five tested did not have any documentation to support that the University verified the subrecipient was not suspended or debarred at the time of executing the subaward agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the subrecipient was neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation retained to ensure the SAM verification was done prior to executing the subaward agreement. In addition, there was no documentation of a second review to ensure the subrecipient was not suspended or debarred. Cause: The control system to prevent payment to a suspended and debarred vendor was not in place. Effect: The University could have entered into a covered transaction with a subrecipient who is suspended or debarred. Repeat Finding: No. Recommendation: We recommend the University review its existing policies to ensure it is up to date with federal regulations. We also recommend documenting the subrecipient was checked on the SAM.gov website prior to executing the subaward agreement. A secondary review should be performed prior to payment. This second review should be documented and retained to support the suspension and debarment requirements were followed and completed before entering into a covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.