Finding 2025-003 – L. Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Information on Federal Program(s) – From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals (ALN 10.237) Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to System for Award Management (SAM.gov). The subaward/subcontract was subject to reporting under the Transparency Act and therefore any related subaward agreements/amendments/modifications were to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The subaward agreement/amendment/modification was not submitted within the required time frame. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The subaward agreement was not submitted within the required time frames resulting in the University not being in compliance with special reporting requirements. Questioned Costs – None. Context – We tested the one subaward subject to FFATA requirements during the year. The University did not submit the subaward agreement within the required time frame on SAM.gov. Indication of Repeat Finding – No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to subrecipient reporting. Views of Responsible Officials – The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountability and Transparency Act. Specifically, the University did not submit a first-tier subaward agreement/amendment/modification within the required timeframe to the System for Award Management (SAM.gov). The University will implement the following corrective actions to address the identified deficiencies: • Internal audit oversight and governance • Enhanced tracking and monitoring systems • Strengthening policies and procedures • Improved interdepartmental coordination • Training and capacity building • Pre-submission review and quality assurance By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2025-001 – N. Special Tests and Provisions – Enrollment Reporting – Program Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 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 SFA 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; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The condition was as follows: Program Level: For certain students that had enrollment status changes, the University incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – The context is as follows: Program Level: • For 2 of 25 students selected for testing, the program enrollment effective date was incorrectly reported. Indication of Repeat Finding – This is a partial repeat of prior year finding 2024-001. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are accurate and submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University will implement the following corrective actions to address the identified deficiencies: • Establishment of an internal audit function • Process review and cross-functional collaboration • Staffing and resource enhancements • Implementation of monitoring and control systems • Strengthening reporting protocols • Training and accountability measures By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2025-002 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063 and 84.268) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 2 of 6 students selected for return of Title IV funds testing. Indication of Repeat Finding - This is a repeat of prior year finding 2024-003. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges Finding 2025-002 regarding noncompliance with federal requirements governing the timely return of Title IV funds. This finding, which represents a repeat of prior year Finding 2024-003, is taken with the utmost seriousness. The University is committed to implementing immediate and sustainable corrective actions to ensure full compliance with all applicable federal regulations. The University will implement the following corrective actions to address the identified deficiencies: • Establishment of an internal audit function • Strengthening interdepartmental communication • Implementation of technological solutions • Process standardization and internal controls • Staffing, training and accountability By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.