FINDING 2025-005 Federal Program Information: Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – 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). 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 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 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. Campus Level: Institutions are responsible for accurately 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full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with 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: We noted the following exceptions: • For 21 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. • For 4 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date. • For 22 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days. • For 8 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements. • Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2025 fiscal year. Identification as a 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 significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the University Registrar and the Registrar is responsible for providing enrollment files to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submit the enrollment file report to the National Student Loan Database System (NSLDS). Howard moved to Workday Student as the University’s ERP beginning with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday. with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” there would be no configuration issues that affect compliance. It was not possible for the Registrar’s Office to fully test enrollment reporting prior to "go live" due to students needing to be registered in courses to send a test file to NSC. At the start of the Fall 2024 semester, Howard worked closely with National Student Clearinghouse to troubleshoot issues that could delay the enrollment files transmission in August and September 2024. This setup of the one-time migration between Workday and NSC was not completed timely. The appropriate individuals from the Registrar’s Office, Office of Financial Aid, National Student Clearinghouse are working together to enable ongoing communication and monitoring of reporting requirements. These parties will work together to confirm student enrollment statuses are reported timely and accurately. The transition to Workday Student allowed the University to review each program of study to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program start date and program length are reported to NSLDS. The effective enrollment date reflected in NSLDS for the four students with the incorrect program start date was fed from the University’s prior ERP, Banner, and all program start dates have now been accurately updated in Workday. The implementation of Workday and staffing transitions in the Registrar's Office caused delays in students being cleared for graduation and then to NSC. The issue for Graduate reporting should not recur due to resolved implementation issues with Workday. Monthly enrollment reporting schedules were set up in NSC for the 2025-2026 academic year during Summer 2025. These enrollment reporting schedules will be updated each summer for the upcoming academic year. Graduation files are scheduled to be transmitted on the first of every month to National Student Clearinghouse. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day reporting timeline will be met. The Office of the Registrar is in constant communication with the representative from NSC when there are questions on reporting student enrollment statuses accurately. Bi-semester reviews by the Associate Director for Compliance will ensure any potential issues in reporting are identified and resolved timely. A review of students reported to NSC for Spring 2025 was completed with a specific focus on students who had a change in enrollment. This review discovered the Workday configuration did not pick up students who dropped courses during the semester in the enrollment file. This configuration issue in Workday has now been corrected. A review of students’ enrollment status for Fall 2025 after the University’s drop/add period showed students in the enrollment reporting file were reported correctly on the Fall 2025 First of Term enrollment file sent to NSC.
FINDING 2025-006 Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain 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. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition: Certain Federal Work-Study (“FWS”) payments were not adequately supported by the respective time records. 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: For 4 of 40 FWS payments tested, the FWS timesheets did not support FWS earnings for pay period tested. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-005. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that student timesheets are appropriately reviewed. Views of Responsible Officials: The Offices of Undergraduate Studies, Financial Aid, Human Resources, and Payroll have worked to re-configure our Enterprise Resource Planning system, Workday, to significantly reduce early time approval and minimize incorrect time attribution. We introduced new controls on May 7, 2025, and provided additional training throughout Academic Year 2024-2025. Although we have made much progress, we are still working to minimize FWS program risks. Specifically, we have noticed that retrofitting the staff and faculty hiring system may not be an ideal solution for handling the unique needs of the Federal Work Study program. As such, we are working with our official Workday partner to enact a distinct student hiring portal, that will also leverage Workday. We expect that this portal will be more nimble and better able to address FWS program management and controls. The expected launch date is Fall 2026.
FINDING 2025-007 Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, 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 15 of the year in which a school submits its FISAP. Condition: The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures. Cause: Insufficient internal controls and administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with special reporting requirements. Questioned Costs: None. Context: The University was unable to provide documentation corroborating the amount reported for Federal Perkins Loan Program cash on hand. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-006. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials: Federal Perkins Loan program records are traditionally paper based, as a result, these school records can often be inconsistent. Due to inconsistent data transfer during Howard University’s move from Campus Partners to ECSI (Educational Computer Systems, Inc.) as the Perkins Loan servicer after the 2013-2014 academic year, the University’s Perkins disbursement data did not match the records Howard had from ECSI. In 2022, the University began to work with ECSI on converting the Howard internal records to match ECSI’s records. In mid-April 2026, ECSI notified Howard that the conversion of ECSI Perkins disbursement data to Howard disbursement data was complete. Currently, the adjustments ECSI made to match Howard are being reviewed by the Associate Director for Compliance in Enrollment Management, and feedback will be provided to ECSI. Matching Perkins Loan data between Howard and ECSI will strengthen the data consistency on the FISAP. The consistency of Perkins Loan data between ECSI and Howard University on the FISAP will also assist in strengthening internal controls for determination of the Cash on Hand amount. ECSI works with schools whose general ledger Cash on Hand does not match what is on the FISAP in Part III. It was conveyed by ECSI that it is more important to have awareness of what data does not match and why than to have parity. After the conversion of Perkins data from ECSI has been approved, the Associate Director for Compliance will meet with Director of Accounting to begin the process of reviewing Perkins wind-down procedures and the accounting related. Howard University is in the process of liquidating the Federal Perkins Program. Due to staffing changes, the Director of Student Billing and Engagement, is now responsible for the Federal Perkins Loan liquidation process. The University is working with ECSI and the Department of Education to complete the liquidation. As part of the liquidation process, the Director of Billing and Engagement contacted the Department of Education to determine the remaining steps for Perkins liquidation. 13 Perkins Loans remaining need to be assigned. Howard is in the process of determining if these loans can be assigned to ED or if the school will need to purchase them.
FINDING 2025-008 Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Insufficient internal control and administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 3 of 25 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-007. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students. Views of Responsible Officials: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. The Bursar’s Office was not able to fully test the Title IV refunds process prior to "go live" due to the inability to disburse and create refunds to be sent to the University’s bank, JP Morgan. In August 2024, the Bursar’s Office identified configuration issues with JP Morgan where parents were not associated with students’ IDs and addresses in delivered refund files sent to JP Morgan Chase. These Title IV checks and direct deposits could not be sent to parents until JP Morgan completely migrated to Workday, in September 2024. After this date, there have not been issues with the JP Morgan Chase configuration with Workday. Workday is a date-driven ERP. Meal charges for Spring 2025 were placed on the students’ account, the due date for payment on the referenced meal charges was put in Workday as 12/23/2025 instead of 12/23/2024. This due date is when the charge is factored into the application of payments for the Office of the Bursar. The result was that housing charges were not being applied for the Spring 2025 semester until the error was discovered by the University during reconciliation. These meal charge dates were corrected to 12/23/2024 in March 2025. Internal controls have been created where there is a second level of review of due dates for charges placed on the students’ account. Due dates for charges during a semester are now reviewed by the Bursar and Housing to ensure the application of payments will pick up all charges for a semester. There are also continuing corrective actions being taken to best capture students who were eligible for a Title IV refund and deliver Title IV credit balances to students within the 14-day timeframe, including the use of reports available in Workday. Beginning with Fall 2025 semester, the on-demand “SF Refund Review Report” in Workday is used to identify students that are eligible for a Title IV refund. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. There are also more Howard University staff focused on the Title IV credit balance process and more stages of approval required for the process to be completed. A list of Title IV credit balance refunds is captured from the “SF Refund Review Report,” the settlement run of refunds are reviewed by the refund approver in the Office of the Bursar, then the refund listing goes to the University Bursar for approval. After approval by the University Bursar the listing of students who will receive Title IV refunds by direct deposit and/or check is sent to the Treasury Specialist for approval. Once the Treasury Specialist approves the refunds, the Cash Manager approves the transmittal of this information to JP Morgan, and the funds are then transmitted to JP Morgan for delivery to parents and students. There has also been identification of a backup employee in the Bursar’s Office and Treasury responsible for the Title IV refund process. These backups have been trained so there is no disruption to the workflow, and they are currently running the Title IV credit balance delivery process when there is a workload balance need to do so to ensure timely refunds. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management have taken place which complement the additional levels of review put in place by the Bursar. An internal review of 10 Title IV refunds sent to students for Summer 2025 was completed in July 2025. A review of 100 students who received refunds for Summer 2025 and Fall 2025 was completed in August 2025. All the students who received a refund for the Fall 2025 semester had their Title IV credit balance delivered timely. A review of 86 Title IV refunds for Fall 2025 completed in October 2025 showed that 0 students in the sample received their Title IV refund past the 14-day timeline.
FINDING 2025-009 Federal Program Information: Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - 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, FPL funds, 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: Certain loan disbursement notifications were not sent timely. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. Context: For 3 of 60 loan disbursements selected for testing, the notification was not sent to the borrower within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-008. Recommendation: We recommend the University enhance its internal controls, policies and procedures over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” in Fall 2024 there would be no configuration issues that affect compliance. Workday was not configured to send out Parent Plus Loans, therefore, Parent Plus notifications were as the result sent out as part of a manual process through the Financial Aid email box. Research into the issue and continued discussions with Workday consultants determined that Parent Plus disbursement notifications definitively cannot be sent out automatically after disbursement in Workday as a result of a flaw in Workday’s configuration capabilities. As a result, “FA CR Parent PLUS Disbursement Notification” report is run weekly out of Workday to identify all Parent Plus Loan disbursements, and a notification is sent to the parent’s email address on file through the Financial Aid Loans team email box. The three disbursement notifications that were not sent out within the 30-day timeline resulted from these Parent PLUS Loans not being shown on the “FA CR Parent PLUS Disbursement Notification” report. These disbursement notifications were originally sent to the student’s email address through Workday instead of being sent to the parent’s email address. While these disbursement notifications were sent timely, a compliance review of disbursement notifications discovered the Workday configuration was sending out some Parent PLUS Loan disbursement notifications to the student’s email address. This left the PLUS disbursement off the “FA CR Parent PLUS Disbursement Notification.” Upon discovery of this configuration error, the Loans Team worked with the University’s Workday consultant to prevent any Parent PLUS Loan disbursement notifications from being sent out through Workday. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management are ongoing. The error with Parent PLUS Loan notifications being sent to the wrong individual in Workday was identified in the March 2025 disbursement notification compliance review. An August 2025 review of disbursement notifications for medical students resulted in there being no disbursement notifications found that were sent past the 30-day timeline and they were sent to the correct individuals. A September 2025 review of disbursement notifications was completed and resulted in enhancements to the mail merge template used to manually send out the Parent PLUS Loan disbursement notifications. An updated mail merge template was created, tested and implemented. A November 2025 disbursement notification review was completed to ensure the Parent PLUS notifications went out timely and to the parent’s email address.
FINDING 2025-010 Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – 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. Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For certain students identified through our testing, the University did not report disbursements through the COD website within the required timeframe. Certain origination records contained inaccurate data. 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: • For 3 of 60 disbursement records tested, the University did not timely report the disbursement to COD. • For 4 of 60 origination records tested, the University did not accurately report all key items. Identification as a Repeat Finding: No similar findings identified in the prior year. 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: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained.
FINDING 2025-011 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 3 of 10 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation supporting an appropriate procurement process. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: While we acknowledge that this represents a repeat finding, the Corrective Action Plan conveys a multi-year remediation strategy that focuses on policy transparency, system controls, staffing capacity, training, and accountability mechanisms. The University will continue to address the execution and adoption challenges across Accountable Units. Since the prior audit cycle, the University has strengthened preventive controls to eliminate reliance on post-transaction modifications or corrections. The Corrective Action Plan addresses policies and procedures, OPC capacity and expertise, training and outreach, monitoring, and accountability. The Corrective Action Plan is structured to reduce reliance on detective measures and facilitate preventive compliance. Consequently, the University expects future audit cycles to yield favorable results.
FINDING 2025-012 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: We noted the following exceptions: • For 1 of 19 equipment purchases tested, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership. • For 6 of 19 equipment purchases tested, the respective property record was either missing an asset identifier, or the asset identifier did not match the physical asset tag. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-010. Recommendation: We recommend that the University strengthen controls over federally owned equipment by ensuring all applicable equipment is promptly and appropriately tagged to indicate federal ownership in accordance with federal regulations. In addition, the University should enhance procedures for maintaining property records by ensuring that disposition information is timely, accurate, and complete. This should include clearly defined roles and responsibilities, documented review and reconciliation processes, and periodic monitoring to ensure equipment records remain current and compliant with federal property management requirements. Views of Responsible Officials: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in WorkDay, and ongoing communications with Suppliers and internal stakeholders. Detective and corrective controls have been established through quarterly exception reporting, monthly equipment purchase audits, and completion of a University-wide physical inventory, and required follow-up to locate, tag, or correct asset records. Moreover, the corrective action plan aims to establish an integrated, sustainable control environment. With documented procedures, active monitoring, customer communications, training, and management oversight, the University expects future audit cycles to yield favorable results.
FINDING 2025-013 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: Certain publications did not include proper acknowledgment of funding or disclaimer as required. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: For 3 of 8 publications tested, the publication did not include the required acknowledgement of support or disclaimer. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-011. Recommendation: We recommend that the University implement formal procedures and controls to verify that publications supported by federal awards appropriately acknowledge funding sources and include required disclaimers prior to release. Management should document review and approval of publications and periodically monitor compliance to ensure adherence to sponsor and federal requirements. Views of Responsible Officials: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgment of federal support and a disclaimer that the contents reflect the authors' responsibility and not that of the sponsoring agency. As this is a repeat finding, the University has undertaken a comprehensive, multi-pronged corrective strategy to ensure sustained compliance going forward. Responsibility for publication acknowledgment and disclaimer compliance now resides with the Sponsored Programs Office (SPO) Pre-Award, in collaboration with the University Library. Key actions completed to date include: a formal Standard Operating Procedure finalized and approved in November 2025; mandatory publication compliance training with a required 80% passing score, serving as a prerequisite for new award setup effective November 2025; a Principal Investigator (PI) Acceptance Memo requiring signature within five business days of each award kickoff meeting to reinforce PI awareness of publication responsibilities; quarterly compliance communications issued to all federally funded PIs; and a dedicated publication compliance category added to the OOR ticketing system to streamline intake and support documentation. During Award Kickoff Meetings, acknowledgment and disclaimer requirements specific to each award are reviewed directly with the PI. SPO Pre-Award and the University Library conduct ongoing reviews of federally funded publications using available bibliometric tools, with periodic spot checks. PIs who do not meet training requirements are subject to a hold on proposal submissions until compliance is verified.
FINDING 2025-014 Federal Program Information: Research and Development Cluster (various ALN #’s), USAID Foreign Assistance for Programs Overseas (ALN 98.001), Charles B. Rangel International Affairs Program (ALN 19.020) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings certifications. In addition, documentation to support certain cost allocations could not be provided. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed or appropriately monitored during the six-month period ended June 30, 2025. Questioned Costs: None. Context: • For the Research and Development Cluster, 19 of 40 employees tested did not complete a time and effort certification for the period selected. • For the Charles Rangel Program, 9 of 10 employees tested did not complete a time and effort certification for the period selected. • For the USAID Program, 6 of 10 employees tested did not complete a time and effort certification for the period selected. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-012. Recommendation: We recommend that the University strengthen its internal controls over effort certifications for federally funded grants by establishing formal procedures to ensure timely completion, review, and monitoring of required certifications. This should include clearly defined roles and responsibilities, automated reminders or tracking mechanisms, periodic management review to identify missing or overdue certifications, and documented follow up procedures to ensure compliance with federal requirements supporting payroll costs charged to federal awards as required. Views of Responsible Officials: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle. Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel.
FINDING 2025-015 Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - per 2 CFR Part 200.305(b)(3), when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the federal agency or pass-through entity reasonably believes the request to be improper. M. Subrecipient Monitoring – per 2 CFR Part 200.332(e)(1), a pass-through entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must review financial and performance reports. Additionally, in accordance with 2 CFR 200.332(g), a pass-through entity must verify that a subrecipient is audited as required by Subpart F of Part 200. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. The University was unable to provide documentation evidencing appropriate, annual review of its subrecipients’ Single Audit reports. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with the requirements for pass-through entities. Questioned Costs: None. Context: • For 3 of 23 subrecipient payments tested, the University was unable to provide documentation evidencing appropriate review by the principal investigator. • For 6 of 23 subrecipients payments tested, payment was not made within the required timeframe. • For 7 of 7 subrecipients tested, the University was unable to evidence its verification of whether an audit had been performed. Identification as a Repeat Finding: This is a repeat of prior year finding 2024-013. Recommendation We recommend that the University enhance subrecipient monitoring controls by implementing documented invoice review protocols and enforcing annual audit verification procedures for all subrecipients. Management should define responsibilities for these reviews, document oversight activities performed, and implement monitoring controls to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitoring, Howard University is implementing the following: • The University is currently piloting a new Supplier Invoice Portal, launched jointly by the Sponsored Programs Office and the Office of Procurement, to improve invoicing efficiency and compliance. Under this new process, subrecipients will be required to submit invoices electronically in accordance with the terms and conditions of their subawards. The portal will support a streamlined review and approval process, with invoices routed through an automated workflow to ensure timely review and disbursement. • To support completion of the University’s annual audit verification requirements for subrecipients, oversight will occur at multiple stages throughout the subaward lifecycle. This includes reviewing audit reports at the proposal development stage, during which subrecipients are required to complete a Subrecipient Commitment Form (implemented September 2025) prior to proposal submission. • At the award stage, refreshed due diligence will be conducted, including a re-review of the subrecipient’s Single Audit and/or financial statements. Finally, the Post Award Compliance team will perform an annual review of subrecipients’ audit reports and complete audit follow up procedures as necessary.
FINDING 2025-016 Federal Program Information: USAID Foreign Assistance for Programs Overseas (ALN 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: Certain expenditures were not converted using an appropriate exchange rate. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Overpayment of federal funds. Questioned Costs: Below reportable threshold. Context: For 2 of 25 expenditures tested, the University used an inaccurate exchange rate in its reimbursement claims. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance review controls over reimbursement claims to ensure accurate exchange rates are consistently applied and supported by appropriate documentation. Views of Responsible Officials: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently.
FINDING 2025-017 Federal Program Information: Student Financial Assistance Cluster (ALN: Various), Research and Development Cluster (ALN: Various), Annual Appropriation (ALN 84.915A), Constitutional Law Chair Endowment (ALN 16.000), Matching Endowment (84.000), Law School Clinical Endowment (ALN 84.998D), USAID Foreign Assistance for Programs Overseas (ALN 98.001), Charles B. Rangel International Affairs Program (ALN 19.020) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - According to federal regulations (2 CFR 200.512(a)(1)), the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor’s report(s) or nine months after the end of the audit period (whichever is earlier). Condition: The University did not submit the June 30, 2025 Single Audit to the Federal Audit Clearinghouse by the required deadline. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with Single Audit reporting deadlines. Questioned Costs: None. Context: The University did not submit the June 30, 2025 Single Audit to the Federal Audit Clearinghouse by the required deadline. Identification as a Repeat Finding: This is a repeat of prior year finding 2024-002. Recommendation: We recommend that the University strengthen its internal controls over the Single Audit reporting process to ensure required audit reports are submitted to the Federal Audit Clearinghouse and respective cognizant agencies in accordance with federal deadlines. This should include establishing a formal compliance calendar, clearly defining roles and responsibilities for report submission, implementing management review and approval procedures prior to filing, and performing periodic monitoring to ensure compliance. Views of Responsible Officials: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report to the Federal Audit Clearinghouse, Howard University will enhance cross collaboration across the University to improve audit readiness. During the May 2025 transition from the Grants and Contracts Accounting Office to the Sponsored Awards Office, the University experienced significant staff turnover and a loss of institutional knowledge, which contributed to audit readiness challenges. Since that time, the University has focused on stabilization efforts. The Office of Research Sponsored Programs has been restructured and is now almost fully staffed. The University will be establishing monthly check ins with key stakeholders to ensure adherence to a compliance calendar with clearly defined roles and responsibilities across core compliance areas. Additionally, the University has hired a Director of Post Award Compliance and Training to lead audit readiness efforts, strengthen internal controls, and support ongoing monitoring and compliance throughout the fiscal year.
FINDING 2025-018 Federal Program Information: USAID Foreign Assistance for Programs Overseas (ALN 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 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 unable to fully reconcile advance payments received from the sponsor to certain expenses incurred during the year. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with cash management requirements. Questioned Costs: None. Context: For 4 of 25 expenditures tested, the University was unable to reconcile the expenditure to the related sponsor payments received. Identification as a Repeat Finding: No similar findings noted 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. Views of Responsible Officials: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In response to the auditor’s recommendation to strengthen internal controls, Howard University will implement procedures to document and reconcile all cash payments received from sponsors on a quarterly basis to actual expenses incurred. This reconciliation process will help ensure that sponsor payments are fully accounted for and appropriately matched to related expenditures, thereby enabling the University to clearly demonstrate which expenses have been reconciled to payments received.