Finding 2025-002 – C. Cash Management Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268) and Federal Pell Grant Program (ALN: 84.063) Criteria or Specific Requirement - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition – Instances were identified where Title IV funds drawn were held in excess of the allowable time frame. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect - The University was not in compliance with Cash Management requirements. Questioned Costs – None. Context – During our audit procedures, we noted 2 instances of cash held in excess of the allowable time frame for the year ended June 30, 2025. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-002. Recommendation – We recommend the University enhance its procedures and internal controls to ensure that excess cash is returned timely. Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls to ensure accurate, timely, and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in, so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws the appropriate amount of federal financial aid. The student accounts billing coordinator applies aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any student that is entitled to a refund will be cut for a refund check that day. The students will then have a window of opportunity to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.
Finding 2025-003 – N. Special Tests and Provisions – Enrollment Reporting Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 84.063 and 84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify 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 (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. 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 NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit them to NSLDS. Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements. Questioned Costs – None. Context – The context of this finding is as follows: • For 1 of 40 campus level records and 14 of 40 program level records tested, the University did not accurately report all enrollment data elements. • For 2 of 40 program level records, the University did not certify the student’s enrollment status within the required timeframe. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-003. Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS. Views of Responsible Officials – In response to Finding 2025-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005, Finding 2023-005 and continued with the Finding 2024-003. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005, 2023-005, and 2024-003. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices.
Finding 2025-004 – N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notifications Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition – During our testing, we identified one borrower who was not notified timely of Federal Direct Student Loans credited to their account. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect - The University was not in compliance with loan disbursement notification requirements. Questioned Costs – None. Context – For 1 of 40 disbursements tested, the University did not notify the borrower within the required timeframe. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-004. Recommendation – We recommend the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials – We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. There was one student that was at 31 days and this process has been updated.
Finding 2025-005 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379) Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – Return of funds was not properly calculated and returned. Questioned Costs – None. Context – For 2 of 2 students tested, the University did not accurately determine the amount to return. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-005. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations. Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The R2T4 process has been working correctly following our R2T4 policy to make sure the days are correct in the system before the R2T4 is submitted. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.
Finding 2025-006 – N. Special Tests and Provisions – Disbursement to or on Behalf of Students – Federal-Work Study Information on Federal Program(s) – Federal Work-Study Program (ALN 84.033) Criteria or Specific Requirement – Federal regulations (34 CFR 675.19(b)) require institutions to establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. Condition – Certain student timesheets were not appropriately reviewed and approved. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements. Questioned Costs – None. Context – 3 of 40 timesheets tested were not certified by the student’s supervisor. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-007. Recommendation – We recommend the University enhance its procedures and internal controls to ensure that all Federal Work-Study related timesheets are appropriately reviewed and approved. Views of Responsible Officials – The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed. Once the new HR and Payroll leader arrived, she instituted this approval process and requirement and checks and balances. Staff are trained in these processes upon hiring as well.
Finding 2025-007 – L. Reporting – Financial Reporting Information on Federal Program(s) – Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement – Federal regulations (34 CFR 668.164(b)(3)(iii)) require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Condition – For certain students identified through our testing, the University did not report disbursements through the COD website within the required timeframe. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds. Questioned Costs – None. Context – 2 of 40 disbursements tested were not reported within the required timeframe. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-008. Recommendation – We recommend the University enhance its procedures and internal controls to ensure timely and accurate reporting of Title IV disbursements. Views of Responsible Officials – Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and that we stay in compliance with the Department of Education reporting requirement.
Finding 2025-008 – N. Special Tests and Provisions – Perkins Loan Record Keeping and Record Retention Information on Federal Program(s) - Federal Perkins Loan Program (ALN 84.038) Criteria or Specific Requirement – In accordance with 34 CFR 674.19, institutions must retain original or true and exact copies of promissory and master promissory notes, repayment records, and cancellation and deferment requests for each Federal Perkins Loan Program (“Perkins”) loan made. An institution shall retain disbursement and electronic authentication and signature records for each loan made using a master promissory note for at least three years from the date the loan is canceled, repaid, or otherwise satisfied (34 CFR 674.19(e)(3)(i)). Condition – For certain Perkins loans, the University could not locate the original promissory notes that contained all the necessary information, including signatures. In addition, the University was unable to provide a record of retired loans. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect - The University was not in compliance with the Perkins loan recordkeeping and record retention requirements. Questioned Costs – None. Context – For 8 of 25 borrowers tested, the University was unable to provide documentation evidencing proper retention of loan records. In addition, the University was unable to provide a record of retired loans. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-009. Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure proper retention of Perkins loan records. Views of Responsible Officials – Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we can submit Perkins information/files to the Department of Education. We have gathered information (promissory notes, bankruptcy details, payment information, etc.) as we have been able to locate it, and we have sorted account in alpha order to assist ECSI with the process. We will continue to update this process.
Finding 2025-009 – L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Criteria or Specific Requirement – In accordance with 34 CFR 676.19, an institution is required to submit the FISAP annually by October 1st, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15th of the year in which a school submits its FISAP. Condition – The University submitted the 2024-2025 FISAP with an error, and data correction was not submitted by the required deadline. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – Noncompliance with reporting requirements. Questioned Costs – None. Context – The University submitted the annual FISAP for the 2024-2025 reporting year by the required deadline; however, Perkins cash on hand reported did not agree to the audited financial statements. The window to correct the 2024-2025 FISAP has closed; as of the date of our Single Audit report, the error remains uncorrected as of the date of this report. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-010. Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that the FISAP is accurately completed prior to submission. Views of Responsible Officials – The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. ECSI has been updated with the Cash on Hand documents that we have from the Department of Education. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education.
Finding 2025-010 – B. Allowable Costs/Cost Principles Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859) Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented. Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – Noncompliance with documentation of payroll and non-payroll expenditure standards. Questioned Costs – Below reportable threshold. Context – Context is as follows: • Payroll Expenditures: For 4 of 4 employees selected for testing, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls. • Non-Payroll Expenditures: For 2 of 8 expenditures selected for testing, the University was unable to provide adequate documentation to fully substantiate the expenditure balance. We also noted that the University did not have formalized internal controls over indirect costs charged to the federal programs. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-011. Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained. We also recommend that the University enhance its internal controls over compliance to ensure all non-payroll expenditures are fully supported as required. Views of Responsible Officials – The University acknowledges that the internal controls surrounding the allowable costs during fiscal year 2025 were lacking and needed to be reinforced for future fiscal years. With the hire of the new CFO and HR leader post June 30, 2025 – these enhanced controls and processes have been put in place, and all payroll and other expenses are detailed, supported, and filed appropriately.
Finding 2025-011 – C. Cash Management Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859) Criteria or Specific Requirement - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Condition – The University was not able to provide reconciliations of funds drawn to expenditures incurred for certain funds drawn down during the current year that reconciled the amounts properly. Additionally, as formal draw down to expenditure reconciliations were not properly performed for certain draw dawns, instances were identified in which the University drew down funds twice for the same expenditure. The combination of the above also resulted in the University not minimizing the time between the date of drawdowns and the date the funds were used. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with cash management requirements. Questioned Costs – None. Context – For 9 of 28 cash draws, the University did not properly perform formal reconciliations of funds drawn to expenditures. Additionally, 3 of 28 cash draws included certain expenditures for which funds were previously drawn, resulting in duplicative cash draws for the same expenditures. The above resulted in excess cash being drawn during the year ended June 30, 2025. Indication of Repeat Finding – No similar finding identified in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that cash draws are properly reconciled to expenditures, that cash draws are only made once for each expenditure, and that time is minimized between cash draws and payment of expenditures incurred. Views of Responsible Officials – The University acknowledges that the internal controls surrounding the cash draws during fiscal year 2025 were lacking and needed to be reinforced for future fiscal years. With the hire of the new CFO and Senior Accountant post June 30, 2025 – these enhanced controls and processes have been put in place.