FAC Explorer

Audit 350395

FY End
2024-06-30
Total Expended
$13.71M
Findings
30
Programs
6
Organization: McKendree University (IL)
Year: 2024 Accepted: 2025-03-30
Auditor: Cliftonlarsonallen LLP (cla)

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
540696 2024-001 Significant Deficiency Yes N
540697 2024-002 Significant Deficiency Yes E
540698 2024-003 Significant Deficiency Yes L
540699 2024-001 Significant Deficiency Yes N
540700 2024-002 Significant Deficiency Yes E
540701 2024-003 Significant Deficiency Yes L
540702 2024-001 Significant Deficiency Yes N
540703 2024-002 Significant Deficiency Yes E
540704 2024-003 Significant Deficiency Yes L
540705 2024-001 Significant Deficiency Yes N
540706 2024-002 Significant Deficiency Yes E
540707 2024-003 Significant Deficiency Yes L
540708 2024-001 Significant Deficiency Yes N
540709 2024-002 Significant Deficiency Yes E
540710 2024-003 Significant Deficiency Yes L
1117138 2024-001 Significant Deficiency Yes N
1117139 2024-002 Significant Deficiency Yes E
1117140 2024-003 Significant Deficiency Yes L
1117141 2024-001 Significant Deficiency Yes N
1117142 2024-002 Significant Deficiency Yes E
1117143 2024-003 Significant Deficiency Yes L
1117144 2024-001 Significant Deficiency Yes N
1117145 2024-002 Significant Deficiency Yes E
1117146 2024-003 Significant Deficiency Yes L
1117147 2024-001 Significant Deficiency Yes N
1117148 2024-002 Significant Deficiency Yes E
1117149 2024-003 Significant Deficiency Yes L
1117150 2024-001 Significant Deficiency Yes N
1117151 2024-002 Significant Deficiency Yes E
1117152 2024-003 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $10.31M Yes 3
84.063 Federal Pell Grant Program $3.08M Yes 3
84.033 Federal Work-Study Program $143,238 Yes 3
84.007 Federal Supplemental Educational Opportunity Grants $93,764 Yes 3
84.038 Federal Perkins Loan Program_federal Capital Contributions $71,176 Yes 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $14,461 Yes 3

Contacts

Name Title Type
V92NBJ823E53 Shari Keffer Auditee
6185376838 Kyla Greenhoe Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 BASIS OF PRESENTATION Accounting Policies: NOTE 1 BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of McKendree University (the University) and under a program of the federal government for the year ended June 30, 2024. The accompanying notes are an integral part of the Schedule. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. NOTE 2 BASIS OF ACCOUNTING Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustment or credits made in the normal course of business to amounts reported as expenditures in prior years. The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of McKendree University (the University) and under a program of the federal government for the year ended June 30, 2024. The accompanying notes are an integral part of the Schedule. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University.
Title: NOTE 2 BASIS OF ACCOUNTING Accounting Policies: NOTE 1 BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of McKendree University (the University) and under a program of the federal government for the year ended June 30, 2024. The accompanying notes are an integral part of the Schedule. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. NOTE 2 BASIS OF ACCOUNTING Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustment or credits made in the normal course of business to amounts reported as expenditures in prior years. The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustment or credits made in the normal course of business to amounts reported as expenditures in prior years. The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: NOTE 3 OUTSTANDING LOANS Accounting Policies: NOTE 1 BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of McKendree University (the University) and under a program of the federal government for the year ended June 30, 2024. The accompanying notes are an integral part of the Schedule. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. NOTE 2 BASIS OF ACCOUNTING Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustment or credits made in the normal course of business to amounts reported as expenditures in prior years. The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The federal loan program listed subsequently are administered directly by the University, and balances and transactions relating to these programs are included in the University’s consolidated financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. The balance of loans outstanding at June 30, 2024 consists of the following: Assistance Listing Number 84.038 Program Name Fderal Perkins Loan Program Outstandin Balance $ -

Finding Details

Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through 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 (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.