2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-006 ? Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (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, you 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 do not 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 and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: ? 1 student out of a sample of 40 students tested did not have a record at NSLDS. ? 1 student out of a sample of 40 students tested, the student?s program per the University did not agree to NSLDS program-level detail. ? 3 students out of a sample of 40 students tested were reported to the NSLDS with an enrollment effective date different than what was included in the University?s records at the campus-level and program-level in NSLDS. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect status at the campus-level and program-level. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect effective date at the program-level. ? 6 students out of a sample of 40 students tested were not reported to the NSLDS at least every 60 days. Cause: 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: Incorrect reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-009. 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: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-005 ? Need Base Calculation Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.200(a)(2)(i) states a direct subsidized loan borrower must demonstrate financial need in accordance with title IV, part F of the Act which is cost of attendance minus the expected family contribution minus other estimated financial assistance that is not Title IV. Condition: Three students demonstrated no financial need due to the inclusion of other estimated non need based financial assistance that incorrectly was improperly included as need-based aid. Questioned Costs: None. Context: Three of 40 students had an incorrect input into the financial need calculation. This calculation would only impact Direct Subsidized Loans. The students were properly awarded and disbursed Direct Subsidized Loans, but the inputs of the calculation were incorrect. Cause: The Other Financial Assistance included a scholarship that should not have been included in the calculation of financial need. Including this scholarship made the student's need zero. Effect: A student could have been under awarded aid due to improper calculation of need. Repeat Finding: Yes, 2021-008 Recommendation: We recommend that the University review the inputs of the calculation of need to ensure the non-need-based financial assistance is not included in need-based amounts. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-006 ? Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (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, you 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 do not 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 and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: ? 1 student out of a sample of 40 students tested did not have a record at NSLDS. ? 1 student out of a sample of 40 students tested, the student?s program per the University did not agree to NSLDS program-level detail. ? 3 students out of a sample of 40 students tested were reported to the NSLDS with an enrollment effective date different than what was included in the University?s records at the campus-level and program-level in NSLDS. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect status at the campus-level and program-level. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect effective date at the program-level. ? 6 students out of a sample of 40 students tested were not reported to the NSLDS at least every 60 days. Cause: 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: Incorrect reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-009. 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: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-010 ? Reporting Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 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. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University did not comply with the requirements for reporting under HEERF. Questioned Costs: N/A. Context: During testing of the reporting requirements for HEERF, the following was noted: ? 2 out of 2 quarterly reports tested for Student HEERF were not completed and posted to the University website. ? 2 out of 2 quarterly reports tested for Institutional HEERF were not posted to the University website in the required timeframe. ? Inaccurate information was reported in the annual report. Approximately $1 million was reported as grants applied to settle a student?s outstanding account balance in error and the University could not supply support for the number of students who received emergency financial aid grants. Cause: Turnover at the University caused reports to be posted late, not completed, or support not kept for reports completed. Effect: Failure to support or file the required reports timely may result in the loss of funding. Repeat Finding: Yes, 2021-014 Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-011 ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the 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 is 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. The Code of Federal Regulations, 2 CFR 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. Condition: The University did not utilize all funds drawn down therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: N/A. Context: During testing of the cash management requirements, 2 draw downs out of a total of 5 tested were not spent in their entity. $14,719,854 of funds were drawn in January 2022, as of June 30, 2022, $8,423,447 had not been disbursed. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement, or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: No Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-010 ? Reporting Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 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. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University did not comply with the requirements for reporting under HEERF. Questioned Costs: N/A. Context: During testing of the reporting requirements for HEERF, the following was noted: ? 2 out of 2 quarterly reports tested for Student HEERF were not completed and posted to the University website. ? 2 out of 2 quarterly reports tested for Institutional HEERF were not posted to the University website in the required timeframe. ? Inaccurate information was reported in the annual report. Approximately $1 million was reported as grants applied to settle a student?s outstanding account balance in error and the University could not supply support for the number of students who received emergency financial aid grants. Cause: Turnover at the University caused reports to be posted late, not completed, or support not kept for reports completed. Effect: Failure to support or file the required reports timely may result in the loss of funding. Repeat Finding: Yes, 2021-014 Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-011 ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the 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 is 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. The Code of Federal Regulations, 2 CFR 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. Condition: The University did not utilize all funds drawn down therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: N/A. Context: During testing of the cash management requirements, 2 draw downs out of a total of 5 tested were not spent in their entity. $14,719,854 of funds were drawn in January 2022, as of June 30, 2022, $8,423,447 had not been disbursed. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement, or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: No Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-006 ? Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (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, you 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 do not 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 and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: ? 1 student out of a sample of 40 students tested did not have a record at NSLDS. ? 1 student out of a sample of 40 students tested, the student?s program per the University did not agree to NSLDS program-level detail. ? 3 students out of a sample of 40 students tested were reported to the NSLDS with an enrollment effective date different than what was included in the University?s records at the campus-level and program-level in NSLDS. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect status at the campus-level and program-level. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect effective date at the program-level. ? 6 students out of a sample of 40 students tested were not reported to the NSLDS at least every 60 days. Cause: 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: Incorrect reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-009. 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: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-005 ? Need Base Calculation Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.200(a)(2)(i) states a direct subsidized loan borrower must demonstrate financial need in accordance with title IV, part F of the Act which is cost of attendance minus the expected family contribution minus other estimated financial assistance that is not Title IV. Condition: Three students demonstrated no financial need due to the inclusion of other estimated non need based financial assistance that incorrectly was improperly included as need-based aid. Questioned Costs: None. Context: Three of 40 students had an incorrect input into the financial need calculation. This calculation would only impact Direct Subsidized Loans. The students were properly awarded and disbursed Direct Subsidized Loans, but the inputs of the calculation were incorrect. Cause: The Other Financial Assistance included a scholarship that should not have been included in the calculation of financial need. Including this scholarship made the student's need zero. Effect: A student could have been under awarded aid due to improper calculation of need. Repeat Finding: Yes, 2021-008 Recommendation: We recommend that the University review the inputs of the calculation of need to ensure the non-need-based financial assistance is not included in need-based amounts. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-007 ? Credit Balances Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period: or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Six students had credit balances that were not refunded within the 14-day period. Questioned Costs: N/A. Context: Through our testing of 40 students, we noted that 6 students did not have the credit balance refunded within the 14-day period. Cause: The University's policies and procedures did not capture all students who had refunds on their student accounts due to Title IV monies. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: Yes, 2021-010. Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-008 ? Outstanding Refund Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(l), requires the University to return to the ED any Title IV funds, except FWS program funds, that were unsuccessfully disbursed to the student or parent. Condition and Context: During the testing of student refund check reconciliations, it was noted that 292 student refund checks were not returned to the ED within the 240-day deadline. Additionally, the University was unable to provide a listing of uncashed check related to Title IV programs after June 30, 2021. Questioned Costs: $246,269 Cause: The University?s cash reconciliation procedures did not identify the checks as having to be returned within the 240-day requirement. Effect: The University could owe funding to the ED due to delays in returning student refund checks. Repeat Finding: Yes, 2021-011. Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Award Identification Number and Year: P007A210811, P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.57(d), if a student is selected for verification, the ED requires the obtain specified documentation. As part of V4 and V5 verification an applicant must provide proof of their identify through a statement of educational purpose. In completing this requirement, the copies of required verification can be received electronically or electronic signature. Condition: 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Questioned Costs: N/A. Context: During our testing, we noted 2 students out of a sample of 5 students tested did not have required support on file for V4 and V5 verification. Cause: The University was unable to obtain the statement of educational purpose from the student. Effect: Noncompliance with verification regulations. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around verification to ensure that required student information is obtained. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-006 ? Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P211233 and P268K211233 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (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, you 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 do not 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 and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: ? 1 student out of a sample of 40 students tested did not have a record at NSLDS. ? 1 student out of a sample of 40 students tested, the student?s program per the University did not agree to NSLDS program-level detail. ? 3 students out of a sample of 40 students tested were reported to the NSLDS with an enrollment effective date different than what was included in the University?s records at the campus-level and program-level in NSLDS. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect status at the campus-level and program-level. ? 3 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect effective date at the program-level. ? 6 students out of a sample of 40 students tested were not reported to the NSLDS at least every 60 days. Cause: 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: Incorrect reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-009. 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: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-010 ? Reporting Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 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. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University did not comply with the requirements for reporting under HEERF. Questioned Costs: N/A. Context: During testing of the reporting requirements for HEERF, the following was noted: ? 2 out of 2 quarterly reports tested for Student HEERF were not completed and posted to the University website. ? 2 out of 2 quarterly reports tested for Institutional HEERF were not posted to the University website in the required timeframe. ? Inaccurate information was reported in the annual report. Approximately $1 million was reported as grants applied to settle a student?s outstanding account balance in error and the University could not supply support for the number of students who received emergency financial aid grants. Cause: Turnover at the University caused reports to be posted late, not completed, or support not kept for reports completed. Effect: Failure to support or file the required reports timely may result in the loss of funding. Repeat Finding: Yes, 2021-014 Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-011 ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the 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 is 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. The Code of Federal Regulations, 2 CFR 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. Condition: The University did not utilize all funds drawn down therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: N/A. Context: During testing of the cash management requirements, 2 draw downs out of a total of 5 tested were not spent in their entity. $14,719,854 of funds were drawn in January 2022, as of June 30, 2022, $8,423,447 had not been disbursed. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement, or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: No Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-010 ? Reporting Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 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. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University did not comply with the requirements for reporting under HEERF. Questioned Costs: N/A. Context: During testing of the reporting requirements for HEERF, the following was noted: ? 2 out of 2 quarterly reports tested for Student HEERF were not completed and posted to the University website. ? 2 out of 2 quarterly reports tested for Institutional HEERF were not posted to the University website in the required timeframe. ? Inaccurate information was reported in the annual report. Approximately $1 million was reported as grants applied to settle a student?s outstanding account balance in error and the University could not supply support for the number of students who received emergency financial aid grants. Cause: Turnover at the University caused reports to be posted late, not completed, or support not kept for reports completed. Effect: Failure to support or file the required reports timely may result in the loss of funding. Repeat Finding: Yes, 2021-014 Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2022-011 ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425J200019, P425F203028 and P425E201388 ? all grants were awarded within 2020-2021 and 2021-2022 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the 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 is 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. The Code of Federal Regulations, 2 CFR 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. Condition: The University did not utilize all funds drawn down therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: N/A. Context: During testing of the cash management requirements, 2 draw downs out of a total of 5 tested were not spent in their entity. $14,719,854 of funds were drawn in January 2022, as of June 30, 2022, $8,423,447 had not been disbursed. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement, or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: No Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.