Finding 2022-001: Significant Deficiency ? Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University?s interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections.
Finding 2022-002: Significant Deficiency - COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Reporting Program: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E and 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E201560 and P425F201058 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: Incorrect data was reported in two institutional portion quarterly reports and the annual report. Three student portion quarterly reports were not posted to the University?s website. One student portion quarterly report and two institution quarterly reports were posted to the University?s website after the 10 days after quarter end requirement. The annual report was also submitted late. The auditor selected a sample of one student portion quarterly report and two institutional portion quarterly reports in addition to the annual report. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The University?s internal control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late or missing posting of the quarterly reports to the University?s website. The University noted there was confusion and misunderstanding on the HEERF reporting requirements including deadlines and whether reports were to be cumulative or not. Effect: The University had HEERF quarterly reporting on its website and annual reporting to the Department that were missing and/or incorrect and/or late. Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: The University concurs with the finding. The University experienced challenges during COVID limiting the availability of resources to review and adequately analyze the reporting guidance as it developed. As a result, there were some misunderstanding of the requirements as they changed over time. The University continued to experience challenges with staffing in 2022 that limited the availability of resources to address the past and current reporting issues. The University will assign more resources to address all reporting issues including updating the website, revising and resubmitting past reports, and submitting missing reports.
Finding 2022-002: Significant Deficiency - COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Reporting Program: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E and 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E201560 and P425F201058 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: Incorrect data was reported in two institutional portion quarterly reports and the annual report. Three student portion quarterly reports were not posted to the University?s website. One student portion quarterly report and two institution quarterly reports were posted to the University?s website after the 10 days after quarter end requirement. The annual report was also submitted late. The auditor selected a sample of one student portion quarterly report and two institutional portion quarterly reports in addition to the annual report. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The University?s internal control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late or missing posting of the quarterly reports to the University?s website. The University noted there was confusion and misunderstanding on the HEERF reporting requirements including deadlines and whether reports were to be cumulative or not. Effect: The University had HEERF quarterly reporting on its website and annual reporting to the Department that were missing and/or incorrect and/or late. Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: The University concurs with the finding. The University experienced challenges during COVID limiting the availability of resources to review and adequately analyze the reporting guidance as it developed. As a result, there were some misunderstanding of the requirements as they changed over time. The University continued to experience challenges with staffing in 2022 that limited the availability of resources to address the past and current reporting issues. The University will assign more resources to address all reporting issues including updating the website, revising and resubmitting past reports, and submitting missing reports.
Finding 2022-001: Significant Deficiency ? Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University?s interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections.
Finding 2022-002: Significant Deficiency - COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Reporting Program: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E and 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E201560 and P425F201058 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: Incorrect data was reported in two institutional portion quarterly reports and the annual report. Three student portion quarterly reports were not posted to the University?s website. One student portion quarterly report and two institution quarterly reports were posted to the University?s website after the 10 days after quarter end requirement. The annual report was also submitted late. The auditor selected a sample of one student portion quarterly report and two institutional portion quarterly reports in addition to the annual report. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The University?s internal control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late or missing posting of the quarterly reports to the University?s website. The University noted there was confusion and misunderstanding on the HEERF reporting requirements including deadlines and whether reports were to be cumulative or not. Effect: The University had HEERF quarterly reporting on its website and annual reporting to the Department that were missing and/or incorrect and/or late. Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: The University concurs with the finding. The University experienced challenges during COVID limiting the availability of resources to review and adequately analyze the reporting guidance as it developed. As a result, there were some misunderstanding of the requirements as they changed over time. The University continued to experience challenges with staffing in 2022 that limited the availability of resources to address the past and current reporting issues. The University will assign more resources to address all reporting issues including updating the website, revising and resubmitting past reports, and submitting missing reports.
Finding 2022-002: Significant Deficiency - COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Reporting Program: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E and 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E201560 and P425F201058 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: Incorrect data was reported in two institutional portion quarterly reports and the annual report. Three student portion quarterly reports were not posted to the University?s website. One student portion quarterly report and two institution quarterly reports were posted to the University?s website after the 10 days after quarter end requirement. The annual report was also submitted late. The auditor selected a sample of one student portion quarterly report and two institutional portion quarterly reports in addition to the annual report. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The University?s internal control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late or missing posting of the quarterly reports to the University?s website. The University noted there was confusion and misunderstanding on the HEERF reporting requirements including deadlines and whether reports were to be cumulative or not. Effect: The University had HEERF quarterly reporting on its website and annual reporting to the Department that were missing and/or incorrect and/or late. Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: The University concurs with the finding. The University experienced challenges during COVID limiting the availability of resources to review and adequately analyze the reporting guidance as it developed. As a result, there were some misunderstanding of the requirements as they changed over time. The University continued to experience challenges with staffing in 2022 that limited the availability of resources to address the past and current reporting issues. The University will assign more resources to address all reporting issues including updating the website, revising and resubmitting past reports, and submitting missing reports.