2022-003 ? Perkins Loan Recordkeeping and Record Retention Federal Agency: U.S. Department of Education Federal Program Title: Federal Perkins Loan Program Federal Assistance Listing Number: 84.038 Award Period: 7/1/21 ? 6/30/22 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)). Condition: Original promissory notes were unable to be located. Questioned costs: None. Context: During our testing, we noted 14 instances out of 60 open Perkins loans tested and 11 instances out of 60 retired/assigned loans where the University was unable to locate the original promissory note. Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students in order to ensure that recordkeeping and retention regulations were being followed. Effect: Open loan balances for these loans are not supported by an original promissory note. Repeat finding: Yes, 2021-005. Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Views of responsible officials: Management agrees with the finding.
2022 ? 002 ? Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: An institution shall submit, in accordance with deadline dates established by the Secretary, through federal publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2)). Condition: COD reporting was not completed within the required timeframe. Questioned costs: None. Context: During our testing, we noted 3 instances out of our sample of 40 COD disbursements tested that were reported to the COD outside the required 15-day timeframe. Cause: The University?s process in place to timely report disbursements to COD did not ensure disbursements were reported timely. Effect: COD reporting was outside the 15-day requirement. Repeat Finding: Yes, 2021-004. Recommendation: We recommend the University evaluate its policies and procedures around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding.
2022 ? 002 ? Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: An institution shall submit, in accordance with deadline dates established by the Secretary, through federal publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2)). Condition: COD reporting was not completed within the required timeframe. Questioned costs: None. Context: During our testing, we noted 3 instances out of our sample of 40 COD disbursements tested that were reported to the COD outside the required 15-day timeframe. Cause: The University?s process in place to timely report disbursements to COD did not ensure disbursements were reported timely. Effect: COD reporting was outside the 15-day requirement. Repeat Finding: Yes, 2021-004. Recommendation: We recommend the University evaluate its policies and procedures around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None. Context: During our testing, we noted the following out of our sample of 40 students tested: ? 6 students had effective dates at the campus level that did not agree between the University?s records and the NSLDS ? 5 students were not reported to the campus level record in the NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days. ? 3 students had incorrect effective dates reported at the program level ? 2 students had the incorrect status reported at both the campus and program levels Cause: Process and controls in place for ensuring timely reporting and updating effective dates within the Banner system were not functioning properly. Additionally, the University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2021-002 and 2021-003. Auditors? Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: Management agrees with the finding.
2022 ? 004 ? Procurement and Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Assistance Listing Number: 84.425F Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: When procuring property and services under a Federal award, entities must follow the procurement standards outlined in 2 CFR 200.218 through 200.327. Included in these requirements, a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University has implemented formal, written policies and procedures to align with the requirements for procurement and suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 5 transactions for procurement and suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s procurement and suspension and debarment policies. Cause: The University experienced turnover during the year and documentation could not be located. Effect: Supporting documentation could not be located to support required procurement and suspension and debarment standards were followed. Repeat Finding: No. Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding.
2022-003 ? Perkins Loan Recordkeeping and Record Retention Federal Agency: U.S. Department of Education Federal Program Title: Federal Perkins Loan Program Federal Assistance Listing Number: 84.038 Award Period: 7/1/21 ? 6/30/22 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)). Condition: Original promissory notes were unable to be located. Questioned costs: None. Context: During our testing, we noted 14 instances out of 60 open Perkins loans tested and 11 instances out of 60 retired/assigned loans where the University was unable to locate the original promissory note. Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students in order to ensure that recordkeeping and retention regulations were being followed. Effect: Open loan balances for these loans are not supported by an original promissory note. Repeat finding: Yes, 2021-005. Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Views of responsible officials: Management agrees with the finding.
2022 ? 002 ? Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: An institution shall submit, in accordance with deadline dates established by the Secretary, through federal publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2)). Condition: COD reporting was not completed within the required timeframe. Questioned costs: None. Context: During our testing, we noted 3 instances out of our sample of 40 COD disbursements tested that were reported to the COD outside the required 15-day timeframe. Cause: The University?s process in place to timely report disbursements to COD did not ensure disbursements were reported timely. Effect: COD reporting was outside the 15-day requirement. Repeat Finding: Yes, 2021-004. Recommendation: We recommend the University evaluate its policies and procedures around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding.
2022 ? 002 ? Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: An institution shall submit, in accordance with deadline dates established by the Secretary, through federal publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2)). Condition: COD reporting was not completed within the required timeframe. Questioned costs: None. Context: During our testing, we noted 3 instances out of our sample of 40 COD disbursements tested that were reported to the COD outside the required 15-day timeframe. Cause: The University?s process in place to timely report disbursements to COD did not ensure disbursements were reported timely. Effect: COD reporting was outside the 15-day requirement. Repeat Finding: Yes, 2021-004. Recommendation: We recommend the University evaluate its policies and procedures around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding.
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None. Context: During our testing, we noted the following out of our sample of 40 students tested: ? 6 students had effective dates at the campus level that did not agree between the University?s records and the NSLDS ? 5 students were not reported to the campus level record in the NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days. ? 3 students had incorrect effective dates reported at the program level ? 2 students had the incorrect status reported at both the campus and program levels Cause: Process and controls in place for ensuring timely reporting and updating effective dates within the Banner system were not functioning properly. Additionally, the University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2021-002 and 2021-003. Auditors? Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: Management agrees with the finding.
2022 ? 004 ? Procurement and Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Assistance Listing Number: 84.425F Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: When procuring property and services under a Federal award, entities must follow the procurement standards outlined in 2 CFR 200.218 through 200.327. Included in these requirements, a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University has implemented formal, written policies and procedures to align with the requirements for procurement and suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 5 transactions for procurement and suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s procurement and suspension and debarment policies. Cause: The University experienced turnover during the year and documentation could not be located. Effect: Supporting documentation could not be located to support required procurement and suspension and debarment standards were followed. Repeat Finding: No. Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding.