Audit 370942

Federal program Federal Direct Student Loans AL #: 84.268 Award Year: 2024/2025 Type of finding Significant Deficiency and Noncompliance Compliance requirement Enrollment Reporting Criteria Under 34 CFR 685.309, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and certify student enrollment status, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website which the financial aid administrator can access for the auditor.Condition An error was identified by the University when completing a return of Title IV funds calculation for a student’s withdrawal in Spring 2025. During the calculation process, the Associate Director of Financial Aid Compliance noticed that the student was reported as withdrawn since 2023, when they were should have been shown as active as they were still attending classes. She brought the error to the attention of the Registrar office, who helped identify the root cause. Although the error was identified during the year, it was not corrected timely. It was subsequently corrected in June 2025. Questioned costs None Context The student’s enrollment status was inaccurately reported as withdrawn since the Fall 2023 semester. Cause A student within one of the University’s graduate programs requested a major change in Fall 2023 which was inaccurately reported by a staff member as a withdrawal. The student’s enrollment status was inaccurately listed within NSLDS as withdrawn since that time rather than active. This error was subsequently corrected in June 2025. Effect The student’s enrollment status was listed correctly within the University’s system, therefore, there was no effect to the accuracy of aid distributed or return of funds. Repeat finding No Recommendations We recommend that the University have controls in place to review the status change information included in the batch reports prior to uploading the data to NSLDS to ensure that all required reporting is completed timely and accurately. View of responsible officials The University has implemented data checks for program/plan issues as part of our 12th class day reporting/clean-up. Institutional Research will run these with their other data checks. Any records flagged for errors and anomalies will be reviewed and corrected by the Registrar’s Office including any updates to enrollment reporting with the National Student Clearinghouse. The University also implemented targeted training for staff in the Brite Divinity School on accurate plan code assignment and its direct impact on enrollment reporting. The enhanced training and communication protocols will significantly reduce the risk of similar human errors.

Federal program Federal Pell Grant Program AL #: 84.063 Award Year: 2024/2025 Type of finding Significant Deficiency and Noncompliance Compliance requirement Enrollment Reporting Criteria Under 34 CFR 685.309, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website which the financial aid administrator can access for the auditor. Condition We noted one out of forty judgmentally selected students the withdrawal date per PeopleSoft was accurate at 10/3/2024 and it was inaccurately reported as 10/30/2024 into NSLDS. The error was corrected by the Associate Director of Financial Aid Compliance (within NSLDS) and Assistant Registrar (within NSCH) when identified in June 2025. Questioned costs None Context The student’s withdrawal date was inaccurately reported to NSLDS due to human error. Cause When performing enrollment reporting for return of funds students, the Student Financial Aid office (SFA) uses a tracking worksheet to document critical data and ensure communication between SFA and the Registrar. When SFA transcribed information from the return of funds worksheet to the tracking worksheet, a 0 was inadvertently added from the withdrawal date of 10/3 to 10/30. Then, that tracking worksheet was used to perform NSLDS enrollment reporting, with the incorrectly transcribed date being entered into NSLDS. This error was caused by human error. Effect The student’s withdrawal date was listed correctly within the University’s system, therefore, there was no effect to the accuracy of aid distributed or return of funds. This is strictly an enrollment reporting error and as a result, the student’s Campus Level and Program Level screens within NSLDS were inaccurate. Repeat finding NoRecommendations We recommend that the University have controls in place to review the status change information included in the batch reports prior to uploading the data to NSLDS ensure that all required reporting is completed timely and accurately. View of responsible officials It was discovered that for one student a transcription error was made when transcribing the LDA (last date of attendance) from the student’s return of funds worksheet to SFA’s and Registrar’s enrollment tracking document of return of funds students. This student was an unofficial withdrawal at the end of the Fall 2024 semester. The Compliance Officer created a RT24 workflow tracking worksheet to identify enrollment reporting dates and ensure communication between SFA and the Registrar. This includes, but is not limited to, unofficial withdrawals with a LDA, all Fs with a LDA, and Q drops with an LDA. There may be other reasons there will be different enrollment dates, and those are also charted. The Compliance Officer will now run a query from PeopleSoft that pulls return of funds information directly from the PeopleSoft worksheet. This query will be imported into a tracking worksheet to ensure accurate enrollment reporting dates. This new tracking worksheet will remove the need for any additional manual updates to enrollment data tracking and reduce the possibility of future transcription errors.

Federal programs Federal Pell Grant Program AL #: 84.063 Award Year: 2024/2025 Type of finding Significant Deficiency and Noncompliance Compliance requirement Program Eligibility Criteria Under 34 CFR § 668.8, an eligible “short-term” program that requires a minimum of 10 weeks of instruction, beginning on the first day of classes and ending on the last day of classes or examinations; is at least 300 clock hours but less than 600 clock hours; provides undergraduate training that prepares a student for gainful employment in a recognized occupation; and admits as regular students some persons who have not completed the equivalent of an associate degree must have a substantiated completion rate of at least 70 percent and a substantiated placement rate of at least 70 percent. The University must calculate the completion and placement rate based on the information outlined in 34 CFR § 668.8(e)(1)(i) and (ii). In addition, the University must obtain evidence to document that each student determined to have obtained gainful employment in a recognized occupation used in the placement rate calculation and ensure that the students’ status is properly reflected in the completion calculation. Condition One student enrolled in the ranch management short-term program selected for testing had inconsistencies in their enrollment status reported by the ranch management program and enrollment information that was reflected in the student’s PeopleSoft account. The University is not calculating the completion and placement rate based on the requirements outlined in the 34 CFR § 668.8(e)(1)(i) and (ii). Questioned costs $39,277 Context The University’s is not calculating the completion and placement rates or properly maintaining students’ enrollment information for short-term programs. Cause The ranch management department is maintaining documentation that reflects the short-term program students who received their certification and were employed; however, the documentation is not shared to the Registrar’s office, resulting in inconsistencies between the students’ enrollment status in PeopleSoft and documentation maintained by the department. In addition, the documentation does not calculate the completion and placement rate based on the requirements outlined in the Compliance Supplement and 34 CFR § 668.8(e)(1)(i) and (ii). Effect A student who was expelled from the ranch management program was not properly reflected in PeopleSoft, resulting in the University improperly reporting that the student completed and graduated from the program. In addition, the University’s ranch management department maintains a list of students who completed and were hired for this short-term program but the University is not calculating the rate of completion and placement based on the requirements outlined in 34 CFR § 668.8. Repeat finding No Recommendations We recommend that the University implement controls to ensure the required completion and placement calculations are performed for each eligible short-term program and ensure the student information included in the calculation is accurate and properly reflected in PeopleSoft.View of responsible officials The University has found a critical breakdown in communication between the Ranch Management department and the Registrar’s Office, stemming from informal, ad hoc processes that have not scaled with institutional needs. Specifically, there is no formal mechanism to ensure that updates to student statuses for the ranch management program are consistently reported or verified. To prevent recurrence of this issue, a process is being implemented that all Non-Degree programs will now be required to perform formal degree audits within the student information system. This ensures consistency in processing and aligns with practices currently used for degree-seeking students. Targeted training and communication will be provided to all Non-Degree program administrators to ensure clarity on new expectations, tools, and timelines. The Registrar’s Office will conduct periodic audits of non-degree program records to verify compliance and identify any further process improvements.

Federal programs Research and Development Cluster – National Institutes of Health – Drug Abuse and Addiction Research Programs AL #: 93.279 Award Year: 2024/2025 Type of finding Significant Deficiency and Noncompliance Compliance requirement Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Under 2 CFR section 200.430(i), costs of compensation for personal services are allowable to the extent the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policies and practices, follows an appointment made in accordance with non-federal entities rules and written policies, and is determined and supported as provided in 2 CFR section 200.430(i), including that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition We noted one out of forty judgmentally selected payroll transactions included cost for an employee that did not relate to services performed in relation to the grant. Questioned costs $625 Context A portion of an employee’s benefits was improperly charged to the grant. Cause When the University changed their timekeeping platform an academic affairs employees’ compensation was improperly set up in the system which incorrectly allocated their vacation time to this grant. Effect The employee’s vacation time that occurred after the change in the University’s timekeeping platform in March 2025 until the discovery after year end was incorrectly included as compensation and benefits expense within the grant. Repeat finding No Recommendations We recommend that the University ensure controls are in place to adequately review all benefits pay charged to grants to ensure appropriate. View of responsible officials To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.