Finding 2025-003 Federal Programs: TRIO Cluster • Talent Search (ALN 84.044A) • Student Support Services (ALN 84.042A) • Upward Bound (ALN 84.047A) • Hampton Road McNair Program (ALN 84.217A) Federal Award #’s: P044A210601, P042A210893, P047A221291, and P217A220293 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass Through Entity: None Compliance Requirement: Reporting – Performance Reporting Criteria: Grantees of the Student Support Services (SSS) program (OMB No. 1840-0525) must submit an annual performance report (APR) to the U.S. Department of Education (ED) each year of the project period. Section II, Record Structure for Participant List, of the APR includes several key line items that contain critical information. These key line items are: 15. Eligibility 17. First Enrollment Date (at grantee institution) 18. Date of First Project Service 19. College Grade Level (entry into project) 22. Participation Status (during academic year) 23. Enrollment status (at end of the academic year) 24. Academic Standing 27. College Grade Level (at the end of the academic year), and 31. Undergraduate Degree/Certificate Completed at Grantee Institution Grantees of the Upward Bound (UB) program (OMB No. 1840-0826) must submit an annual performance report (APR) to the U.S. Department of Education (ED) each year of the project period. Section II, Record Structure for Participant List, of the APR includes several key line items that contain critical information. These key line items are: 16. Eligibility (at time of initial selection) 17. At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection) 18. At Risk: Low Grade Point Average (at time of initial selection) 19. At Risk: Pre-Algebra or Algebra Course Not Successfully Completed by Beginning of 10th Grade (at time of initial selection) 20. Limited English Proficiency (at time of initial selection) 24 Date of First Project Service 25. Grade Level at First Service 27. Participant Status for reporting year 28. Participation Level for reporting year 29. Served by Another Federally Funded College Access Program for reporting year 30. Grade Level at the beginning of academic year being reported 37. Secondary School Retention and Graduation Objective – Numerator, for reporting year 45. Date of Last Project Service Condition and Context: The University utilizes the Blumen Online for TRIO application in order to summarize and report its performance reporting data for entry into its Annual Performance Report (APR) and submission to the Department of Education. A total sample of 60 students were selected across the four TRIO programs to test the accuracy of the APR. For 11 of 60 students who benefitted from a TRIO program, the following key line items were found to be incorrectly reported in at least one instance; Date of First Project Service, College Grade Level (entry into project), Enrollment Status (at end of academic year), College Grade Level (at the end of the academic year), or Participation Level for reporting year. • For eight of 60 sampled students who benefited from a TRIO program the University inaccurately reported one key line item. • For three of 60 sampled students who benefited from a TRIO program the University inaccurately reported two key line items. Cause and Possible Asserted Effect: The University’s controls to review key line items of SSS and UB data input into Blumen did not operate consistently to ensure that complete and accurate data was reported to the Department of Education on the APR. Identification of Questioned Costs: There were no questioned costs related to this finding. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that the University strengthen its review control over the data input of key line items of SSS and UB data into Blumen and subsequently the APR. Identification of Repeat Finding: This audit finding is a repeat of Finding 2024-005 in the immediately prior year. Views of Responsible Officials: Management agrees with this finding. The director and staff will review the key line item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Prior to submitting the APR, a download of all data categories will be reviewed for accuracy and completeness
Finding 2025-002 Federal Programs: Student Financial Aid Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Award #’s: P268K240395 and P063P230395 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass Through Entity: None Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No.1845-0035). 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 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: (1) OPEID number, (2) enrollment effective date, (3) enrollment status and (4) certification date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: (1) OPEID number, (2) CIP code, (3) CIP year, (4) credential level, (5) published program length measurement, (6) published program length, (7) program begin date, (8) program enrollment status and (9) program enrollment effective date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of 60 students who were recipients of Direct Loans or Pell Grants between July 1, 2024, and June 30, 2025, who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For seven out of the 60 students selected for testwork, the University did not report their enrollment status change within the 60 days of change. • For two out of the 60 students selected for testwork, the University inaccurately reported their enrollment status as half-time or full-time, whereas the University’s enrollment records indicated the students were enrolled at three-quarter-time. • For one out of the 60 students selected for testwork, the graduation enrollment status change was not reported to NSLDS. • For one out of the 60 students selected for testwork, the campus-level enrollment record was not updated to reflect half-time status, resulting in the enrollment status change not being reported to NSLDS within the required 60-day timeframe. Cause and Possible Asserted Effect: The University’s controls over its review of the recording and communication of these status changes did not operate consistently to ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that the University improve its IT processes and functionality so that enrollment statuses are reported completely and accurately. We also recommend strengthening controls over the accuracy and processing of student enrollment status changes. Identification of Repeat Finding: This audit finding is a repeat of Finding 2024-004 in the immediately prior year. Views of Responsible Officials: The University concurs with the finding. We will work with IT to enhance the information included in the Comprehensive Graduation Report to ensure complete, accurate and timely reporting.
Finding 2025-004 Federal Programs: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Award #’s: P268K240395 and P063P230395 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass Through Entity: None Compliance Requirement: Special Tests and Provisions - Disbursements to or on Behalf of Students Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed to the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds are awarded. Condition and Context: The University generates a Title IV refund report following each disbursement date to identify credit balances created on student accounts and facilitate timely refunds in accordance with the required time frame. For 4 out of 40 students selected for testwork, the Title IV funds credited to the students’ accounts resulted in credit balances owed to the students. For 3 of these students, the institution did not refund the credit balances within the required 14-day timeframe and did not obtain proper authorization from the student to retain the balance. The delays in issuing refunds ranged from 15 to 92 days. Additionally, for 1 student, although authorization was obtained to retain the credit balance, the institution did not refund the credit balance by the end of the award year for which the funds were awarded. Cause and Possible Asserted Effect: In the current fiscal year, the University was in the process of implementing enhanced processes related to Title IV returns, and as a result, the controls were not operating effectively. This contributed to the institution’s failure to refund credit balances to students within the 14-day timeframe required by the Department of Education and to obtain voluntary authorization from students to retain credit balances for the semester. Identification of Questioned Costs: There were no questioned costs related to this finding. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: This finding is not a repeat of a finding in the immediately prior year. Recommendation: We recommend that management perform a completeness review of the Title IV refunds to ensure all credit balances are refunded to students within the required 14 day timeframe. In addition, management should review the existing system of controls related to the timely refund of credit balances. Further, management should reinforce control ownership and provide targeted training to individuals responsible for compliance. These actions will help ensure that appropriate controls are in place, responsibilities are clearly defined, and instances of noncompliance are prevented or promptly identified and corrected, thereby supporting effective control operation. Views of Responsible Officials: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund of credit balances. Further, management will reinforce control ownership and provide targeted training to individuals responsible for compliance. The actions will help to ensure that appropriate controls are in place and responsibilities are clearly defined, and instances of noncompliance are mitigated to support controls.