2025 – 001 – Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063; 84.268 Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned costs: None. Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • 9 out of 60 students’ change in status were not reported timely to the NSLDS • 5 out of 60 students’ program begin dates were reported incorrectly to the NSLDS • 1 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records • 1 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records • 1 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records • 2 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2024-001. Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Views of responsible officials: There is no disagreement with the audit finding.
2025 – 002 – Title IV Credit Balance Refund Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.007; 84.033; 84.063; 84.268 Federal Award Identification Number and Year: P007A232562; P007A242562, P063P231812, P063P241812, P268K241812, P268K251812, P033A222562, P033A232562, P033A242562 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Student Title IV credit balances were not refunded within the required 14-day time frame. Questioned costs: None. Context: During our testing, 1 student out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe. Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly. Effect: The University did not refund the student's Title IV credit balance within 14 days as required by Department of Education regulations. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure any credit balances resulting from Title IV aid are returned within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P231812; P063P241812 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the Student Aid Index (SAI) and the enrollment status of the student. Condition: A student was under-awarded Pell funds due to an award calculation error. Questioned costs: $458 Context: During our testing, 1 student out of a sample of 40 was under-awarded Pell due to a calculation error during initial award processing. Cause: The University calculated the student's Pell award incorrectly. Effect: The student was under-awarded Pell funds. Repeat finding: No. Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are performed based on the accurate cost of attendance, SAI and enrollment status of the student. Views of responsible officials: There is no disagreement with the audit finding.
2025 – 004 – Procurement and Suspension & Debarment Federal Agency: U.S. Department of Education Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210072 - 2024 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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. Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance. Questioned costs: None Context: During our testing, suspension and debarment procedures were not performed for 4 of 5 vendors tested. As a result of timing of when the University formalized their written procurement policy, there were no formal procurement procedures performed for 1 of 5 vendors tested. Cause: The University was not following a formalized procurement policy. Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat finding: Yes, 2024-005. Recommendation: We recommend the University follow their policy for procurement and suspension & debarment to ensure they are aligned with Uniform Grant Guidance. Views of responsible officials: There is no disagreement with the audit finding.