Audit 49806

FY End
2022-06-30
Total Expended
$46.17M
Findings
52
Programs
7
Organization: Concordia University, St. Paul (MN)
Year: 2022 Accepted: 2023-03-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
43249 2022-001 Material Weakness - N
43250 2022-002 Significant Deficiency Yes N
43251 2022-003 Significant Deficiency Yes N
43252 2022-005 Significant Deficiency - N
43253 2022-001 Material Weakness - N
43254 2022-002 Significant Deficiency Yes N
43255 2022-003 Significant Deficiency Yes N
43256 2022-005 Significant Deficiency - N
43257 2022-001 Material Weakness - N
43258 2022-002 Significant Deficiency Yes N
43259 2022-003 Significant Deficiency Yes N
43260 2022-005 Significant Deficiency - N
43261 2022-001 Material Weakness - N
43262 2022-002 Significant Deficiency Yes N
43263 2022-003 Significant Deficiency Yes N
43264 2022-005 Significant Deficiency - N
43265 2022-001 Material Weakness - N
43266 2022-002 Significant Deficiency Yes N
43267 2022-003 Significant Deficiency Yes N
43268 2022-005 Significant Deficiency - N
43269 2022-001 Material Weakness - N
43270 2022-002 Significant Deficiency Yes N
43271 2022-003 Significant Deficiency Yes N
43272 2022-005 Significant Deficiency - N
43273 2022-004 Significant Deficiency Yes L
43274 2022-004 Significant Deficiency Yes L
619691 2022-001 Material Weakness - N
619692 2022-002 Significant Deficiency Yes N
619693 2022-003 Significant Deficiency Yes N
619694 2022-005 Significant Deficiency - N
619695 2022-001 Material Weakness - N
619696 2022-002 Significant Deficiency Yes N
619697 2022-003 Significant Deficiency Yes N
619698 2022-005 Significant Deficiency - N
619699 2022-001 Material Weakness - N
619700 2022-002 Significant Deficiency Yes N
619701 2022-003 Significant Deficiency Yes N
619702 2022-005 Significant Deficiency - N
619703 2022-001 Material Weakness - N
619704 2022-002 Significant Deficiency Yes N
619705 2022-003 Significant Deficiency Yes N
619706 2022-005 Significant Deficiency - N
619707 2022-001 Material Weakness - N
619708 2022-002 Significant Deficiency Yes N
619709 2022-003 Significant Deficiency Yes N
619710 2022-005 Significant Deficiency - N
619711 2022-001 Material Weakness - N
619712 2022-002 Significant Deficiency Yes N
619713 2022-003 Significant Deficiency Yes N
619714 2022-005 Significant Deficiency - N
619715 2022-004 Significant Deficiency Yes L
619716 2022-004 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $33.05M Yes 4
84.063 Federal Pell Grant Program $5.54M Yes 4
84.038 Federal Perkins Loan Program $1.24M Yes 4
84.007 Federal Supplemental Educational Opportunity Grants $278,339 Yes 4
84.033 Federal Work-Study Program $133,000 Yes 4
84.425 Education Stabilization Fund $103,990 - 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $60,966 Yes 4

Contacts

Name Title Type
YGV4KC77D6N5 Michael Dorner Auditee
6516418811 Daniel R. Persaud, CPA Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not pass through any funds to subrecipients. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. FEDERAL PERKINS LOAN PROGRAM (84.038) - Balances outstanding at the end of the audit period were 555118.
Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University did not pass through any funds to subrecipients. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. The purpose of the schedule of expenditures of federal awards (the Schedule) is to present a summary of those activities of the Organization that have been financed by the U.S. government (federal awards). Federal awards received directly from federal agencies are included in the Schedule, as are federal guaranteed loans disbursed by other sources. Additionally, all federal awards passed through from other entities have been included in the Schedule. The Organization is required to match certain grant agreements, as defined in the grants, and these matching amounts are not included in the Schedule. The information in the Schedule is presented in accordance with requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Concordia University, St. Paul.

Finding Details

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund Assistance Listing Number: 84.425E ? Higher Education Emergency Relief Fund ? Student Portion 84.425F ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Award Identification Number and Year: P425E203131-20B and P425F203130-20B Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. Additionally, the University was required to submit certain reports relating to their Higher Education Emergency Relief Fund (HEERF) during fiscal year 2022. Condition: During our testing, 1 out of 2 quarterly institutional and 2 out of 2 student quarterly reports, it was noted that the Vice President of Finance prepares the reports but no one reviews the reports before submission. Additionally, it was noted that these reports were not submitted timely. Finally, a few discrepancies were noted as it relates to numbers reported and their underlying support. Questioned costs: None Context: The University had inconsistencies between the student and institutional reports submitted, and the support provided. Cause: The HEERF funding is new to the University and given the complexity, the Vice President of Finance was the only knowledgeable person to prepare these reports. Effect: A few quarterly reports submitted had immaterial discrepancies. Three quarterly reports were also submitted late. Repeat Finding: Yes, Finding 2021-004. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund Assistance Listing Number: 84.425E ? Higher Education Emergency Relief Fund ? Student Portion 84.425F ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Award Identification Number and Year: P425E203131-20B and P425F203130-20B Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. Additionally, the University was required to submit certain reports relating to their Higher Education Emergency Relief Fund (HEERF) during fiscal year 2022. Condition: During our testing, 1 out of 2 quarterly institutional and 2 out of 2 student quarterly reports, it was noted that the Vice President of Finance prepares the reports but no one reviews the reports before submission. Additionally, it was noted that these reports were not submitted timely. Finally, a few discrepancies were noted as it relates to numbers reported and their underlying support. Questioned costs: None Context: The University had inconsistencies between the student and institutional reports submitted, and the support provided. Cause: The HEERF funding is new to the University and given the complexity, the Vice President of Finance was the only knowledgeable person to prepare these reports. Effect: A few quarterly reports submitted had immaterial discrepancies. Three quarterly reports were also submitted late. Repeat Finding: Yes, Finding 2021-004. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 9 of 40 students tested did not have an R2T4 calculation performed when necessary. 3) A net of $3,437 should have been returned to U.S. Department of Education based on individual students? R2T4 calculation but was not. This includes $10,060 of funds that were under returned offset by $6,624 in funds that were overall returned for respective students tested. Questioned costs: $3,437 Context: The University had instances where students left the school but the University did not perform a R2T4 calculation, calculated the R2T4 incorrectly or under/over return federal funds. Cause: The University has had significant turnover and there were no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $3,437. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: No. Auditors? Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 25 of 60 students enrollment information on NSLDS did not match their program information. The institution also must update all records every 60 days, and CLA noted 6 out of 60 students had instances greater than 60 days where their records were not updated. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2021-002. Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that do not pass the NSLDS enrollment reporting edits, an Institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted instances where the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned costs: None Context: The University had instances where the yielded errors were not corrected within the 10 days window. Cause: Management did not resubmit the yielded errors within 10 days on a few instances. Effect: The University was not in compliance with the requirements to timely respond to error reports. Repeat Finding: Yes, Finding 2021-005. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 620.21 states that institutions must report to the Department of Education no later than 10 days after the change occurs any changes in personnel where the person has the ability to affect substantially the actions of the institution. Condition: During our review of the ECAR, we noted that key personnel changes were not reported within the required 10 days. Questioned costs: None Context: The University changed their Student Financial Aid Director in July 2021; however, the ECAR was not updated to reflect the change within the allotted 10-day window. Cause: During our testing, we noted the University did not inform the Department of Education of the personnel changes that occurred in July 2021 when the change took place. Effect: The University is not meeting the requirements for reporting to the Department of Education key contacts for the student financial aid program. Repeat Finding: No. Auditor?s Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund Assistance Listing Number: 84.425E ? Higher Education Emergency Relief Fund ? Student Portion 84.425F ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Award Identification Number and Year: P425E203131-20B and P425F203130-20B Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. Additionally, the University was required to submit certain reports relating to their Higher Education Emergency Relief Fund (HEERF) during fiscal year 2022. Condition: During our testing, 1 out of 2 quarterly institutional and 2 out of 2 student quarterly reports, it was noted that the Vice President of Finance prepares the reports but no one reviews the reports before submission. Additionally, it was noted that these reports were not submitted timely. Finally, a few discrepancies were noted as it relates to numbers reported and their underlying support. Questioned costs: None Context: The University had inconsistencies between the student and institutional reports submitted, and the support provided. Cause: The HEERF funding is new to the University and given the complexity, the Vice President of Finance was the only knowledgeable person to prepare these reports. Effect: A few quarterly reports submitted had immaterial discrepancies. Three quarterly reports were also submitted late. Repeat Finding: Yes, Finding 2021-004. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund Assistance Listing Number: 84.425E ? Higher Education Emergency Relief Fund ? Student Portion 84.425F ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Award Identification Number and Year: P425E203131-20B and P425F203130-20B Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. Additionally, the University was required to submit certain reports relating to their Higher Education Emergency Relief Fund (HEERF) during fiscal year 2022. Condition: During our testing, 1 out of 2 quarterly institutional and 2 out of 2 student quarterly reports, it was noted that the Vice President of Finance prepares the reports but no one reviews the reports before submission. Additionally, it was noted that these reports were not submitted timely. Finally, a few discrepancies were noted as it relates to numbers reported and their underlying support. Questioned costs: None Context: The University had inconsistencies between the student and institutional reports submitted, and the support provided. Cause: The HEERF funding is new to the University and given the complexity, the Vice President of Finance was the only knowledgeable person to prepare these reports. Effect: A few quarterly reports submitted had immaterial discrepancies. Three quarterly reports were also submitted late. Repeat Finding: Yes, Finding 2021-004. Auditor?s Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.