Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement