Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 34 CFR 690.63, institutions must calculate a student's Pell Grant award based on enrollment status and cost of attendance. Condition: During the course of our testing, we identified one student from a sample of 40 who had a Pell grant calculated incorrectly, which resulted in an under-award of $250. The University was not able to specifically identify why it was calculated incorrectly. Cause: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to calculate Pell Awards. Context: Controls did operate properly for the University to disburse Pell funding according to federal schedules. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to calculate Pell Awards. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: Federal Perkins Loan Program Federal Agency: Department of Education Award Year: 2024 Criteria: Universities participating in the Federal Perkins Loan Program must (1) obtain a properly executed promissory note for each loan made and (2) maintain loan records, including the original promissory note (or an imaged copy meeting regulatory standards) and repayment history/supporting documentation, until the loan is satisfied, assigned to the Department of Education (ED), or otherwise resolved. Condition: From a sample of 25 open Perkins loans selected for testing: • The signed Perkins promissory note was not available for 3 of 25 loans tested. • The original repayment documentation (e.g., repayment schedules, statements/correspondence evidencing conversion to repayment, deferment/forbearance approvals where applicable, and payment history artifacts) was not available for 24 of 25 loans tested. Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure proper maintenance of Perkins documentation. Context: Controls were not in place for the University to properly maintain Perkins documentation. Effect: There is an increased risk that the University cannot enforce the loan in the event of dispute or default and may be unable to support amounts reported and collected, potentially resulting in liability for disallowance or required assignment to ED for affected loans. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, and 84.379 Federal Agency: Department of Education Award Year: 2024 Criteria: The University must establish procedures to ensure credit balances arising from the application of federal aid are refunded in accordance with regulations, within 14 days. Condition: In our testing, we found that eight students out of a sample of 25 did not receive their credit balance refunds within the required timeframe, and one student received only a partial refund on time. Cause: The University lacked sufficient internal controls or monitoring procedures to ensure credit balance refunds were processed in a timely manner. Context: Controls were not in place for the University to refund credit balances within the required timeframe. Effect: The University did not meet specific requirements outlined in the FSA Handbook and Federal Code of Regulations regarding the refunds of credit balances to students. Questioned Costs: None Repeat Finding: No Recommendations: It is advised that the University establish and record a comprehensive quality assurance process with appropriate controls to reduce the risk of noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 34 CFR 668.162, institutions must limit Title IV drawdowns to the amount needed to meet immediate disbursement needs. Funds drawn in excess of actual disbursements must be returned to the U.S. Department of Education (DOE) within three business days. Additionally, institutions must reconcile drawn funds with actual disbursements reported in the Common Origination and Disbursement (COD) system. Condition: During the course of our cash management testing, we identified the University drew down Title IV funds in excess of the amounts awarded and disbursed to students. Specifically: • Pell Grant funds totaling $64,976 and $59,913 at different points in the year were drawn but not disbursed within the required timeframe. $13,626 of this remained overdrawn as of June 30, 2024. • Direct Loan funds totaling $296,282 and $121,250 at different points in the year were drawn in anticipation of disbursements that did not occur due to student ineligibility or withdrawal. All funds had been properly distributed as of June 30, 2024. Cause: The University lacked sufficient internal controls and monitoring procedures to ensure that federal funding draws did not exceed the awarded amounts. Context: Controls did not operate properly for the University to disburse funding drawn within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to ensure federal funds drawn did not exceed awarded amounts. Questioned Costs: $13,626 Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Various Award Year: 2024 Criteria: According to 34 CFR 685.301(a)(8), institutions must certify that the information provided to the Secretary is accurate and supported by institutional records. Additionally, 34 CFR 685.309(b) requires institutions to report to the Secretary accurate and complete information necessary for the administration of the Direct Loan Program, including student eligibility, loan amounts, and disbursement data. Condition: During the review of Direct Loan records, it was noted that 4 out of 36 students tested had discrepancies between the underlying support for Cost of Attendance (COA) and/or grade level and the information reported in the Common Origination and Disbursement (COD) system. Cause: The University did not have adequate internal controls or monitoring procedures in place to accurately report student data. Context: Controls did operate properly for the University to properly report student data to COD. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to properly report student data. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, and 84.379 Federal Agency: Department of Education Award Year: 2024 Criteria: Under the Gramm Leach Bliley Act (GLBA) Safeguards Rule, the University must develop, implement, and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards. Condition: The University has not fully implemented or documented controls as required by the Gramm Leach Bliley Act. Specifically, the audit team observed that: • Customer data is not encrypted • Periodic inventories of data are not performed • While an annual risk assessment was performed, which included required elements, many of those elements were not found to be satisfactorily implemented. Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure compliance with the GLBA Act. Context: Controls did operate properly for the University to comply with requirements of the GLBA Act Effect: Failure to implement and enforce access controls increases the risk of unauthorized access to sensitive customer data, potentially leading to data breaches, regulatory penalties, and reputational harm. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 (Pell) and 84.268 (Direct Loans) Federal Agency: Department of Education Award Year: 2024 Criteria: In our initial testing of the completeness of the withdraw population, we identified missing students. As a result, management performed further completeness procedures and identified 11 instances of missing R2T4 calculations. In total, the University calculated $31,830 of Direct Loans and $3,499 of Pell Grant funding as amounts to be returned. Management corrected these; however, they were returned outside the required 45 day timeframe. Condition: In testing the completeness of the withdraw population, we identified 11 instances of missing R2T4 calculations, resulting in late R2T4 returns. In total, the University calculated $31,830 of Direct Loans and $3,499 of Pell Grant funding as amounts to be returned; however, these amounts were not returned within the required 45 day timeframe. Additionally, in a sample of 5 R2T4 recalculations, 3 used incorrect semester dates and/or aid amounts, resulting in: • One student over-returning $75 of loans; • One student under-returning $75 of loans; and • One student with no net impact because the student attended the majority of the semester (the misdated inputs did not change the proration outcome). Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure proper calculations and timely returns for R2T4 funds. Context: Controls did not operate properly for the University to properly calculate R2T4 returns and return aid timely. Effect: Noncompliance with the R2T4 timing requirement increases the risk of ED findings, potential liabilities, and interest assessments for late returns. Additionally, inaccurate R2T4 calculations lead to improper amounts returned on behalf of students and ED. Questioned Costs: $31,830 of Direct Loans and $3,499 of Pell Grant Repeat Finding: Yes Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: TRIO Cluster Federal Assistance Listing Number: 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: According to the Uniform Guidance (2 CFR Part 200) and TRIO program regulations, the University is required to maintain internal controls to ensure federal funds are spent on allowable, allocable, and reasonable expenses that directly support the objectives of the program. Any expenditure that does not meet these criteria may be subject to disallowance or repayment. Condition: During testing of expenditures related to the TRIO program, it was observed that documentation supporting approvals of expenditures and indirect costs was not consistently maintained or approved in accordance with the University ’s internal policy and internal controls. Specifically, invoices and indirect cost calculations were not supported by specific/approved requests and calculations and certain invoices were not formally approved. Cause: The lack of approval and formal calculations appear to stem from inadequate oversight of expense approvals or inconsistent documentation practices. In some cases, personnel responsible for financial management may not have received sufficient training or turnover resulted in a lack of documentation retention noting formal approval. Effect: The University did not have proper internal controls to ensure costs were properly approved in accordance with Uniform Guidance. Questioned Costs: None Repeat Finding: No Recommendations: The University should modify its internal controls to ensure proper approval of federal funds. Implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: TRIO Cluster Federal Assistance Listing Number: 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: According to the Uniform Guidance (2 CFR Part 200) and TRIO program regulations, the University is required to maintain internal controls to ensure the University minimizes the time between the drawdown of federal funds and their disbursement for federal program purposes. The University is required to maintain internal controls to ensure this objective is met and supported. Condition: The University did not maintain proper internal controls over the drawdown of federal funds. Specifically, it was observed that documentation supporting the drawdowns and approval of the drawdowns themselves were not maintained. Management was subsequently able to provide support for the drawdown. Cause: The lack of documentation of support and approval for federal drawdowns appears to stem from inadequate oversight of the federal drawdown process. In some cases, personnel responsible for financial management may not have received sufficient training or turnover resulted in a lack of documentation retention noting formal approval. Context: In our testing, 2 of 2 drawdowns the University initiated did not include support of or evidence supporting the approval of the amounts requested. Management was able to subsequently provide support for the drawdown by providing evidence from the general ledger that supported the amounts requested. Effect: The University did not have proper internal controls to ensure federal drawdowns were supported and approved prior to requesting funds. Questioned Costs: None Repeat Finding: No Recommendations: The University should modify its internal controls to ensure proper support and approval of federal fund drawdowns. Management's Response: Management agrees with the finding. See corrective action plan.
Federal Program: Student Financial Assistance Cluster and Trio Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379, 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 2 CFR §200.512 (Uniform Guidance), auditees must submit the reporting package and Data Collection Form (DCF) to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report, but no later than nine months after the end of the audit period. Condition: The University submitted the DCF after the required deadline: • DCF due date: March 31, 2025 • No documented extension or waiver was obtained. Cause: The University did not have adequate internal controls or monitoring procedures in place to timely submit the DCF. Context: Controls did operate properly for the University to timely submit the DCF. Effect: Increased risk of federal oversight or sanctions for repeated late filings. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.