Assistance Listing Number, Federal Agency, and Program Name Student Financial Aid Cluster (Federal Pell Grant Program 84.063, Federal Direct Student Loans 84.268) Federal Award Identification Number and Year P063P191630, P268K211630, 2024 Pass through Entity N/A Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding No Criteria Under the Direct Loan programs (Direct Loan, 34 CFR Section 685.309) and Federal Pell (Pell, 34 CFR Section 690.83(b)(2)) Condition Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Of the 40 students selected for status change testing, 5 of these students did not have their status continuously reported as withdrawn until their status changed. The students identified were previously reported correctly, within the required time frame. However, a subsequent enrollment roster was erroneously submitted to the National Loan Clearinghouse after the semester had officially ended, causing the enrollment status of these students to revert to their original status prior to the unofficial withdrawal. Cause and Effect A control was lacking to ensure student status changes remained at the appropriate status throughout the semester. Recommendation The University should establish a control to ensure students who withdrew from classes remain reported as withdrawn in the monthly roster files until their status changes. Views of Responsible Officials and Corrective Action Plan Management agrees with this finding. The office of financial aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended.
Assistance Listing Number, Federal Agency, and Program Name Student Financial Aid Cluster (Federal Pell Grant Program 84.063, Federal Direct Student Loans 84.268) Federal Award Identification Number and Year P063P191630, P268K211630, 2024 Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs, and no additional disbursements may be made to the student for the payment period or period of enrollment. Condition Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Questioned Costs The University returned $887 less than the University's calculation and the required return to the federal agency. Identification of How Questioned Costs Were Computed The questioned costs were computed as the difference between the calculated return amount and the amount returned by the University. Context Of the 40 students selected for R2T4 testing, 1 student had the appropriate amount of return calculated correctly, but the appropriate amount was not returned to the federal agency. Upon discovery, the office of financial aid reviewed all required returns completed in the year. The returned amount for the remaining students in the semester matched the University's calculated return. Cause and Effect A control was lacking to ensure R2T4 amounts returned match the amount calculated. Recommendation The University should establish a control to review the amounts calculated compared to the amounts returned to the federal agency. Views of Responsible Officials and Planned Corrective Actions Management agrees with this finding. To prevent human error from occurring in the future, the office of financial aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a senior financial aid advisor or member of the financial aid management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis.
Assistance Listing Number, Federal Agency, and Program Name 93.332 U.S. Department of Health and Human Services Navigator Grants Program Federal Award Identification Number and Year NAVCA210431 02, NAVCA210431 03 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria 2 CFR 200.318 requires that a nonfederal entity that acquires property or services under a federal award or subaward is required to adopt, maintain, and follow written procurement procedures, which comply with sections 2 CFR 200.318 through 327. Condition The University did not follow the written procurement procedures in place. Questioned Costs $686,325 Identification of How Questioned Costs Were Computed Questioned costs reflect the amount of costs expended under the grant during 2024 that exceeded the procurement policy threshold. Context The University did not follow its written policy in place over procurement methods, including using a competitive bid process and reviewing for suspension and debarement for purchases over the policy's threshold. Cause and Effect Failure to comply with the University's written procurement policy, where controls were not in place to comply with the University's policy. Recommendation The University should ensure controls are in place to comply with the procurement policy on an ongoing basis. Views of Responsible Officials and Planned Corrective Actions It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that principal investigators (PIs) with awards with direct costs greater than the University's bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to university purchasing policies. Continued noncompliance may result in corrective actions for the applicable principal investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses.
Assistance Listing Number, Federal Agency, and Program Name 93.332 U.S. Department of Health and Human Services Navigator Grants Program Federal Award Identification Number and Year NAVCA210431 02, NAVCA210431 03 Pass through Entity N/A Finding Type Material weakness Repeat Finding No Criteria During the 2024 single audit, a federal grant was incorrectly included in the Research and Development (R&D) cluster. The grant should have been identified as a separate federal program and tested as a major program in accordance with the Uniform Guidance requirements. Condition Federal programs must be grouped into clusters only when specifically designated by the Office of Management and Budget (OMB). Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context During 2025, fiscal year single audit testing of the 2025 major programs identified that a program was incorrectly included in the R&D cluster when it should have been listed as a separately identified program. Cause and Effect The error occurred due to misclassification of the grant on the schedule of expenditures. As a result, a separately identified program should have been selected as a major program during the 2024 audit and this report must be reissued to reflect the correct classification and testing of the major program. Recommendation Controls over SEFA classification and clustering should be implemented in order to properly present the SEFA. Views of Responsible Officials and Planned Corrective Actions Additional review procedures have been implemented to prevent SEFA classification errors. Specifically, the sponsored research accounting manager now conducts a detailed review of the award documentation prior to SEFA categorization. Furthermore, a verification step has been added to the grant setup checklist, performed by sponsored research accounting staff, to ensure accurate classification of all awards prior to inclusion in SEFA reporting.