Finding 2025‐001 Special Tests and Provisions – Enrollment Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Effect or potential effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Questioned costs: $0 Context: We issued a material weakness related to internal control over compliance with enrollment reporting requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 60 students from the combined population of 1681 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2025. The 60 students, randomly selected, consisted of 35 student graduates, 15 student withdrawals/no shows, and 10 student changes in attendance levels. Of the 10 student changes in attendance levels, 1 student change in attendance level was not reported to the NSLDS. As a result, campus and program level data for program enrollment effective date and status was not reported for this student. For the 35 student graduates and 15 student withdrawals/no shows, the student status changes were reported accurately and timely to NSLDS. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2024-001; 2023-001; 2022-001; 2021-001; 2020-001; 2019-002 Recommendation: The University should review, revise and implement internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes the Registrar’s Office and the Office of Financial Assistance working together to eliminate reporting issues and provide for successful data processing for enrollment reporting. The corrective action will be implemented by May 31, 2026.
Finding 2025‐002 Special Tests and Provisions – Return of Title IV Funds Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans (Direct Loans), ALN 84.268 Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.” Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Cause: The University did not have effective internal controls and procedures in place over the return of Title IV funds to prevent noncompliance. Effect or potential effect: The University is not returning Title IV funds within the required time frame to ED, resulting in noncompliance. Questioned costs: $24,214 – Questioned costs were calculated based on the amount of funds not properly returned to ED. Context: We issued a material weakness related to internal control over compliance for the timely calculation and return of Title IV funds in the prior year. Based upon the planned implementation date for the corrective action of May 31, 2025 and then changed to May 1, 2026, as provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 38 students from the population of 233 students who received Title IV funds, who withdrew during the year ended May 31, 2025. Of the 38 students selected, returns of Title IV funds were required for 26 students, with no returns required for 12 students. For 4 of the 26 students who withdrew, returns of Title IV funds were not returned to ED by the University within 45 days after the date the University determined the student withdrew. For these 4 students Title IV funds were returned to ED within a range of 81 to 142 days after the student withdrew. For 3 of the 26 students who withdrew, no returns of Title IV funds were calculated by the University and therefore no funds were returned to ED by the University. The funds required to be returned but not returned to ED totaled $24,214 for the 3 students. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2024-002; 2023-002 Recommendation: The University should review and revise its internal controls and procedures surrounding the calculation and timely return of Title IV funds to ensure that the correct amount of federal student financial assistance is returned within the required time frame. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the Director of Financial Assistance has been working on a full review of all withdrawals during fiscal year 2023-2024 and 2024-2025 to ensure calculations were complete, accurate, and funds returned as required. The corrective action will be implemented by May 1, 2026.
Finding 2025‐003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). Cause: The evidence of the internal control over award letters being sent to students consisted of award letter job completion confirmation emails. The evidence of the internal control over direct loan notifications includes reports of direct loan disbursements and corresponding dates of direct loan notifications received through the reporting tool, Argos, through email. The University indicated an issue with Outlook caused the emails to be deleted, so we were unable to observe some of the emails related to the award letters and any of the emails related to the direct loan notifications for the fiscal year ended May 31, 2025. Effect or potential effect: Evidence of the performance of internal controls over award letters and direct loan notifications did not exist. Award letters may not be sent, resulting in noncompliance, and direct loan notifications may not be made timely which could impact the student’s ability to cancel the loan. Questioned costs: $0 Context: Once the University prepares award packages for students, the award letter chain is triggered. Once the award letter chain is triggered, an award letter job completion confirmation is received via email by the Office of Financial Aid. We observed award letter job completion confirmation emails for 3 of 9 weeks selected for testing; however, we did not observe award letter job completion confirmation emails for the remaining 6 of 9 weeks selected. The University indicated there was a storage issue with Outlook causing emails to be deleted, including those related to award letter job completion emails. Due to the Outlook storage issue, we were unable to verify which weeks did or did not require award letters to be sent to students or which weeks might have been affected by the storage issue. Although, we did not observe the award letter job completion confirmation emails for 6 selected weeks, we did observe award letters were sent to each of the students selected in our disbursement testing, noting no compliance exceptions. The University receives emails from its reporting tool, Argos, of direct loan disbursements made and corresponding direct loan notification dates. We were unable to obtain the Argos emails containing the direct loan notification reports for 25 selected days. As a result, we could not confirm whether the University received the reports or performed the control to determine if any manual notifications should have been made. According to the University, the storage issue with Outlook caused Loan Disbursement Notification Quality Control emails to be deleted. We observed no such emails dated during the fiscal year ended May 31, 2025. Although we did not observe the email documentation and reports from Argos as evidence that internal controls over direct loan notifications were performed, we did observe direct loan notifications were made for the disbursements to students selected in our disbursement testing, noting no compliance exceptions. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The University should ensure that evidence of the performance of internal controls related to award letters and direct loan notifications is maintained. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan whereby the Office of Financial Assistance is now able to retain evidence of emails related to internal controls over award letters and direct loan notifications. The corrective action was implemented by May 23, 2025.
Finding 2025‐004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds were awarded. Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Cause: The evidence of the internal control over student credit balances includes credit balance reports received through the reporting tool, Argos, through email. The University indicated an issue with Outlook caused the emails to be deleted, so we were unable to observe any of these emails for the fiscal year ended May 31, 2025. Additionally, the University’s internal controls were not effective to ensure that student credit balances were identified and returned to students with 14 days as required. Effect or potential effect: Evidence of the performance of internal controls over the review of student credit balances did not exist. Additionally, due to ineffective controls, the refund of student credit balances were not made timely (within 14 days as required), which resulted in noncompliance. Questioned costs: $0 Context: We were unable to obtain the Argos email containing the report of students with credit balances for the 9 weeks selected. As a result, we could not observe that the University received these reports and performed the internal control of review and inspection of student credit balances to ensure that students received refunds as appropriate. The University indicated there was a storage issue with Outlook causing emails to be deleted, including those related to the credit balance control emails. We observed no such emails dated during the fiscal year ended May 31, 2025. Additionally, we observed noncompliance for 4 of 40 students, whereby 3 students did not receive refunds of credit balances within 14 days and 1 student did not receive a refund of the credit balance, since the University applied the credit to other charges; however, that was done after the 14 day requirement. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The University should ensure that internal controls over the identification and return of student credit balances are improved and effective and also maintain evidence of the performance of those internal controls. The University should ensure that student credits are identified and returned to students within 14 days, as required. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan whereby the Office of Financial Assistance is now able to retain evidence of emails related to internal controls over award letters and direct loan notifications. Additionally, the Business Office is now running internal reports twice weekly to identify and process credit balances. The corrective action was implemented by May 23, 2025.
Finding 2025‐005 – Cash Management Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cash Management Program Requirements for Direct Loans – Monthly Reconciliations Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). Electronic Announcements DL-22-07 and GENERAL-22-86 explain that a school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records (School Account Statements) with the school’s financial and business records. Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Cause: The University did not have effective internal controls and procedures in place to ensure the use of SAS in monthly reconciliations. The University indicated that they used SAS in their monthly reconciliations; however, they did not retain evidence that the SAS was used, including accounting for differences between SAS and the University’s financial and business records. Effect or potential effect: Lack of external monthly reconciliations between the University’s records and SAS could result in incorrect data in the University’s records and ED systems and cash management and disbursement reporting timelines not being met. Questioned costs: $0 Context: While the University provided evidence of internal daily reconciliations, the University did not provide evidence that they utilized SAS for monthly reconciliations, as required. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2023-003 Recommendation: The University should review and revise its internal controls and procedures surrounding the monthly reconciliations to SAS and retain evidence of such reconciliations, including SAS. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the Office of Financial Assistance will maintain evidence of monthly reconciliations between SAS and the University’s financial and business records. The corrective action was implemented by February 1, 2026.
Finding 2025‐006 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318 (i) General Procurement Standards states, “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Condition: The University did not maintain records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Cause: The University did not have effective internal controls and procedures in place to ensure the University maintained records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement and other required elements. Effect or potential effect: The University did not comply with the general procurement standards per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. The University also did not retain evidence of internal controls related to approval of procurements. The performance of internal controls, including approval documentation of the procurement, is necessary to ensure compliance with federal procurement requirements. Questioned costs: $167,398 – Questioned costs were calculated based on the amount of two procurements for which the history of the procurement, including the rationale of the procurement method, was not documented ($73,980 plus $93,418). Context: We issued a material weakness related to internal control over compliance with procurement requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. We selected and tested the two procurements in the population over $10,000 with expenditures totaling $167,398 for the year ended May 31, 2025 for the School Safely National Activities program. For these procurements of an occupational therapist contractor ($73,980) and another vendor for supplies and materials ($93,418), the University did not obtain quotes or document sole source justification or the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. We consider the expenditures related to these procurements to be questioned costs due to lack of supporting documentation for the procurement, as noted above. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $262,030 related to procurements of goods and services during the year, of which 2 procurements were over $10,000. Identification as a repeat finding, if applicable: Yes – 2024-004; 2023-004 Recommendation: The University should retain written documentation for procurements, documenting the history of the procurement prior to the procurement of goods or services including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The University should also retain evidence of internal controls, including approval documentation of the procurement, performed prior to entering into procurements. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the University will document the methodology used to select sole source or preferred vendor procurements through completion of the Sole Source/Preferred Vendor Justification Form. The corrective action will be implemented by March 1, 2026.
Finding 2025‐007 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). In accordance with 2 CFR part 180 non-federal entities are prohibited from contracting with, or making subawards to parties that are suspended or debarred, or otherwise excluded. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The University did not have evidence that the University performed suspension and debarment checks for contractors on SAM.gov prior to entering into the contracts. Cause: The University either did not perform and/or retain evidence of checks for suspension and debarment for contractors. The University does not have a clear written policy or effective internal control over compliance with suspension and debarment requirements. Effect or potential effect: The University did not comply with suspension and debarment requirements. Without having effective internal controls over suspension and debarment, procurements could be entered into with a suspended or debarred entity. Questioned costs: $167,398 – Questioned costs were calculated based on the amount of two procurements for which no check for suspension or debarment was made for the vendors ($73,980 plus $93,418). Context: We issued a material weakness related to internal control over compliance with suspension and debarment requirements in the prior year. Based upon the implementation dates for the corrective action of February 24, 2025 and May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. We selected and tested 2 procurements over $25,000 each with expenditures totaling $167,398, for the year ended May 31, 2025 for the School Safely National Activities program. The procurements were for an occupational therapist contractor ($73,980) and another vendor of supplies and materials ($93,418). The University had no evidence of suspension and debarment checks being performed prior to entering into the procurements. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $167,398 related to contracts or procurements of goods and services over $25,000. Identification as a repeat finding, if applicable: Yes – 2024-005 Recommendation: The University should develop and implement procedures and internal control to ensure that suspension and debarment requirements are complied with, and that support for the dates and the results of suspension and debarment checks on SAM.gov are retained. Also, the University should revise its procurement policy to include procedures for suspension and debarment. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes retention of documentation of suspension and debarment searches on SAM.gov and adding verbiage to contracts/purchase orders related to suspension and debarment. The corrective action was implemented by May 31, 2025.
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications. Cause: The University did not execute their internal controls for the timely preparation and approval of employees’ time and effort certifications on a timely basis. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program due to the delay in the preparation and approval of the time and effort certifications. Level of effort per grant award notification and grant proposal documents may not be met as required for the applicable employees with level of effort requirements, the program director/principal investigator and co-investigators, for the School Safely National Activities Program. Questioned costs: None. Context: It is the University’s policy to have time and effort certifications prepared and approved for grant employees on a semesterly basis. For 9 of 14 payroll expenditures selected for testing, the University’s employees prepared their time and effort certifications between 4 and 10 months after the applicable semester ended, with approvals made after that time. The grant documents provide for level of effort requirements for the program for five employees, including the program director/principal investigator with a level of effort of 25% and 4 co-investigators with level of effort of 2.5%. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $209,270 related to payroll expenditures, including fringe benefits. Identification of a repeat finding: Not applicable. Recommendation: We recommend the University execute its internal controls to provide for the preparation and approval of employees’ time and effort certifications on a timely basis after the end of each semester. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the University updated the time and effort reporting form and the Grants Accounting Office will ensure the forms are completed timely. The corrective action was implemented by February 6, 2026.